Estate Planning & Taxation
Trusts and Estates

Somewhere in a bleak house in Washington, D.C. a plot exists. The conspirators are working against a favorite planning tool, the grantor retailed annuity trust (GRAT). Bill after bill has been born to limit the flexibility and power of the GRAT. The authors of these legislative works have great expectations to oppress this popular idea.

September 1, 2010
Journal of Passthrough Entities

0ne of the more important appellate court valuation cases was handed down in late spring by the Eighth Circuit, T.H. Holman. In this month's column, we analyze the reasoning and how it applies to the structuring of family Iimited partnerships.

Trusts and Estates

A family limited partnership (FLP) and a family limited liability company (FLLC) are two entity choices frequently used by estate planners to achieve federal estate tax (“estate tax”) savings. While many considerations impact the choice of a FLP versus a FLLC,5 one factor that probably escapes consideration by many practitioners is the impact of the passive activity loss (PAL) rules for Federal income tax (“income tax”) purposes on that choice.

Journal of Passthrough Entities

One of the least discussed and reasoned decisions in entity planning for discount purposes is whether to use a limited liability company (LLC) format or that of the family limited partnership (FLP). On the surface, as an LLC is taxed as a partnership under the Internal Revenue Code,1 practitioners often conclude that there should be no difference.

Trusts and Estates

In what kind of Alice in Wonderland world might clients be better off destroying good things like charitable remainder trusts (CRTs)

December 1, 2009
Journal of Passthrough Entities

This month, the column discusses the estate tax strategies for which the grantor trust planning should be considered, including lifetime use of the applicable credit amount, the qualified personal residence trust (QPRT), postmortem use of grantor trusts in the credit shelter trust context, grantor retained annuity trusts (GRATs), and sales to a grantor trust.

Trusts and Estates

Many clients believe that the greatest enemy to their wealth is the federal estate tax. The reality is that very few estates actually pay a federal estate tax and current estimates are that fewer than 20,000 estates annually will actually pay the federal estate tax.

NWSBA

 

Understanding the legal and emotional aspects to billing and collecting for legal services

Journal of Passthrough Entities

One of the most popular passthrough entities used by sophisticated estate planners is the irrevocable grantor trust, set up during the grantor’s lifetime. The importance of the grantor trust for estate planning purposes has been highlighted by the recent revenue ruling, 2008-22.

ESTATE PLANNING

What to do when there's not enough bucks to take care of the financial damage

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