Private Wealth Services Tax Policy Counseling. Nonprofit and Tax-Exempt Organizations Global Private Client. McGuireWoods LLP

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Skip is the former chair of the firm's private wealth services team and current chair of the firm's tax practice. His extensive experience includes estate planning, estate and trust administration, and work with charitable organizations. He works with clients regarding planning for families with closely held businesses, including ownership succession issues; the use of family limited partnerships, limited liability companies, and other techniques to transfer wealth at significantly reduced transfer tax costs; and counseling on the appropriate uses of family offices. Charles D. Fox IV Partner T: +1 434 977 2597 F: +1 434 980 2280 cfox@mcguirewoods.com Court Square Building 310 Fourth Street, N.E. Suite 300 Charlottesville, VA 22902-1288 PRACTICES Private Wealth Services Tax Policy Counseling INDUSTRIES Nonprofit and Tax-Exempt Organizations Global Private Client He has worked for over 25 years with groups interested in reforming the federal tax system, and advises and consults with other law firms on substantive estate planning issues and the administration of their practices. His experience also includes audits of estate tax returns involving unique assets such as art, trust and estate litigation, and the formation and operation of public and private charities, including the formation of charities after the sale of not-for-profit hospitals to for profit corporations. He has worked extensively with corporate fiduciaries on a variety of issues. Skip has contributed numerous articles to many publications including Trusts & Estates, Estate Planning, Trusts & Trustee, and the Journal of Asset Protection. He was a member of the editorial board of Trusts & Estates, and was chairman of the editorial board of Trust & Investments from 2003 to 2012. He also writes a bi-monthly column for American Bankers Association Trust Newsletter. He is a member of the CCH Estate Planning Advisory Committee. He was editor of the ACTEC Journal from 2005-2006. He is the current president-elect of ACTEC. He is the co-editor of Making Sense of the 2010 Estate Tax Legislation (CCH, 2011) and Estate Planning Strategies After Estate Tax Reform: Insights and Analysis (CCH, 2001). He is the author of the Estate Planning with Life Insurance volume of the CCH Financial Planning Library, and co-author of the books Estate Planning Manual (2001 edition), Fiduciary Law and Trust Activities Guide, and Tax Law Guide, all published by the American Bankers Association. He lectures annually around the country at numerous seminars on estate planning and trust administration topics for banks, trust associations, estate planning councils, tax institutes, bar associations and other organizations, including the University of Miami Heckerling Estate Planning Institute and the Notre Dame Estate Planning Institute. He also is the co-presenter of the monthly teleconferences on estate planning and trust administration topics presented by the American Bankers Association since 2001. Skip is a member of the faculty of the National Trust School and the National Graduate Trust School (at which he has taught for over twenty-five years), and was an adjunct professor at Northwestern University Law School from 1983-2005. He is currently an adjunct professor at the University of Virginia School of Law. He serves or has served on the boards of several charities including the University of Virginia Law School Foundation and the Episcopal High School in Virginia, from which he received the Distinguished Service Award in 2001. He is also chairman emeritus of the Duke University Estate Planning Council. McGuireWoods LLP www.mcguirewoods.com 1

EXPERIENCE Represented families with assets ranging from less than a million dollars in value to over two billion in value in all aspects of estate planning with a focus on first learning what the family members want and only then determining the most tax efficient way to accomplish the family members wishes. Represented estates of decedents with difficult to value assets in IRS audits when IRS sought to impose millions of dollars in additional tax. Represented families in the succession of ownership and control from one generation to the next. Represented numerous public and private charities in all aspects from organization, to obtaining tax exempt status, in dealing with donors, to termination. EDUCATION University of Virginia School of Law, JD, 1980 Yale University, MA, 1977 Princeton University, AB, Concentration in Russian Studies, with Distinction, 1975 ADMISSIONS Illinois Virginia HONORS Fellow, American Bar Foundation Named a "Divorce, Trusts and Estates Trailblazer," The National Law Journal, 2016 Named a Notable Practitioner, Private Wealth Law, Band 2, District of Columbia and US Nationwide, Chambers HNW Guide, 2016 Named "Lawyer of the Year," Trusts and Estates, 2012, 2015, 2017; Tax Law, 2016, Charlottesville, Best Lawyers in America, Woodward/White, Inc. Selected for inclusion in The Best Lawyers in America, Litigation Trusts & Estates, Tax Law, Trusts & Estate, Woodward/White, Inc., 2002-2017 Named to "Virginia Super Lawyers," Estate Planning and Probate, Administrative Law, Tax, Super Lawyers, Thomson Reuters, 2006-2017 Selected for inclusion in America's Leading Lawyers for Business, Wealth Management: Eastern Region, Nationwide, Chambers USA, 2009-2016 Elected to National Association of Estate Planners and Councils Estate Planning Hall of Fame and Given Designation of Distinguished Accredited Estate Planner, 2008 Named to "Illinois Super Lawyers," Estate Planning and Probate, Administrative Law, Tax, Super Lawyers, Thomson Reuters, 2002-2005 PUBLICATIONS Author, State Death Tax Chart, July 2017 (revised) Co-author, "IRS Settlement With Carmex Owners Is Surprising," Law360, April 14, McGuireWoods LLP www.mcguirewoods.com 2

2016 Co-author, Making Sense of the 2010 Estate Tax Legislation, CCH, June 2011 Co-author, "2010 Tax Act Impacts Estate Planning," Trusts and Investments, February 2011 Author, "The Human Side of Succession Planning," Private Wealth Magazine, February 2010 Co-author, "Estate Planning In Uncertain Times: The Impact of the Repeal of the Estate Tax and What You Need to Consider," January 1, 2010 Co-author, "The ACTEC State Death Tax Chart: Still Going Strong After Seven Years," ACTEC Journal, Vol. 35, No. 1, Summer 2009 Author, "Estate Planning in 2009: A New Playing Field," Trust and Investments, February 2009 Author, "The Doctor s in, School s in Session," Trust and Investments, June 2008 Author, "Top Ten Ethical Challenges Facing Estate Planners Today and the Best Practices for Addressing Them: 42d Annual Heckerling Institute on Estate Planning," Lexis Nexis, January 2008 Author, "How Revocable is Irrevocable: Obtaining Flexibility in Irrevocable Trusts," 33 Ohio Northern Law Review 943, 2007 Author, "Outright Does Not Always Mean Outright," 32 ACTEC Journal 308, Spring 2007 Author, "International Estate Planning for Trust Professionals," Trust and Investments, February 2007 EVENTS Speaker, "Recent Developments/New Tax Laws," "Issues Confronting Institutional Fiduciaries," 12th Annual Fiduciary Advisory Services Seminar, October 4, 2017 Speaker, "Recent Tax Developments," 11th Annual Fiduciary Advisory Services Seminar, October 5, 2016 Speaker, "Recent Developments," Be a Road Warrior, Not Road Kill: Issues Confronting Fiduciaries, October 7, 2015 Speaker, Recent Developments, The Federal Financial Institutions Examination Council, July 14, 2015 Speaker, Recent Developments, Ohio State Bar, June 25, 2015 Speaker, Tales from the Crypt, Alabama Tax Institute, June 24, 2015 Speaker, "Critical Concepts in Understanding Community Property vs. Common Law," American Bar Association Teleconference, June 4, 2015 Speaker, Family, Finances, & the Future, Creating a Legacy Through Gift Planning, Charlottesville Area Planned Giving Council, May 29, 2015 Speaker, Recent Developments, Who is A Descendant?, Current Charitable Issues and Ethical Considerations in Acting as a Trustee or Executor or Representing a Trustee or Executor, Parkersburg, May 27, 2015 Speaker, Recent Developments; Advanced Planning; Fiduciary Income Tax; Ethics, Star Bank, May 19, 2015 Speaker, Recent Developments, Fiduciary Litigation, Advanced Estate Planning, McGuireWoods LLP www.mcguirewoods.com 3

West Virginia Bankers, May 14, 2015 Speaker, "Recent Updates, Ethics, and Discretionary Distribution Decisions," Fiduciary Education Foundation Convention, May 13, 2015 Speaker, Being a Philanthropist; Donor Advised Funds vs Private Foundations vs. Outright Gifts, Central Arizona EPC, May 11, 2015 Speaker, Recent Developments, University of Virginia Law School, May 8, 2015 Speaker, Recent Developments, UCLA/CEB Estate Planning Institute, May 1, 2015 Speaker, Recent Developments, Charlottesville Area Community Foundation, April 24, 2015 Speaker, "Recent Developments," Kansas City Estate Planning Symposium, April 23, 2015 Speaker, "Show Me the Money: The Focus of States of Tax Revenues and Its Impact on Estate Planning," American Bar Association Teleconference, April 2, 2015 Speaker, "Ethical Challenges for Trust Professionals," American Bar Association Teleconference, March 5, 2015 Speaker, Ethics, The American College of Trust and Estate Counsel, March 5, 2015 Speaker, "Ethics in Estate and Trust Administration," Trust Advisors Forum, February 24, 2015 Speaker, "Monticello," Planned Giving, February 16, 2015 Speaker, "Hot Button Tax Issues for the IRS," American Bar Association Teleconference, February 5, 2015 Speaker, "Welcome and Introduction" and "Recent Developments In Tax," What You Do Not Know Can Hurt You, October 7, 2014 Speaker, "Onshore or Offshore: An Update on Asset Protection Strategies," New Developments in Tax and Wealth Planning, Wednesday, October 30, 2013 Speaker, "Recent Tax Developments" and "Planning in Light of the 2012 Tax Act," Surmounting the Current Challenges: Issues Confronting Professional Fiduciaries, October 10, 2013 Speaker, "Mirror, Mirror on the Wall, What Is Happening to the Estate Tax in 2013 If at All?," 16th Annual Charitable Planning Seminar, The Dallas Foundation, January 25, 2013 Speaker, Who s on First? Issues Confronting Professional Fiduciaries, The Fiduciary Advisory Services Seminar, co-presented by the Fiduciary Education Center, October 9, 2012 AFFILIATIONS Member, Real Property, Probate and Trust Law Section, American Bar Association Member; President-Elect, 2017-2018; Secretary, 2014-2015; Treasurer 2015-; Regent, 2006-2012, 2014-; Co-chair, Legal Education Committee, 2002-2005; Editor, ACTEC Journal, 2005-2006; Chair, Editorial Board, 2008-2009; Chair, Communications Committee, 2010-2011; Member, Communications Committee, Estate and Gift Tax Committee, Legal Education Committee and Program Committee, American College of Trust and Estate Counsel Member, CCH Financial and Estate Planning Advisory Board, 2004-present McGuireWoods LLP www.mcguirewoods.com 4

Member, Central Virginia Estate Planning Council, 2006-present Member, Chicago Estate Planning Council, 1990-2005 Member, 1986-present; Chair, 2008-2013; Chair Emeritus, 2013-, Duke University Estate Planning Council Chair, Economics of the Practice, Subcommittee, 1993-1997; Member, Editorial Board, 1996-2001, Trusts and Estates Magazine Member, Editorial Board, 2001-2003; Chair, Editorial Board, 2003-2012, Trust and Investments Magazine The McGuireWoods website provides information of general interest to the public. The website does not offer legal advice about specific situations or problems. You should consult a McGuireWoods lawyer if you have legal issues requiring attention. Nothing on this site creates an express or implied contract. McGuireWoods does not intend to create an attorney-client relationship by inviting you to contact us. Unless and until we and you agree that we will represent you, we will not have any duties to you, including any duty to keep what you send us confidential or any duty to protect your interests. This means that nothing you send us will be kept confidential, unless we mutually agree that we will keep it confidential. Past legal successes described on this website are not indicators of future results. The outcome of particular legal matters is dependent upon the facts and law applicable to the matters. McGuireWoods LLP www.mcguirewoods.com 5