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Never Can Say GoodbyeNever Can Say Goodbye
One of the defining characteristics of closely held business owners is their need to control. This need prevents many from using lifetime transfer strategies, leaving only testamentary approaches, which are inherently less transfer tax efficient. Obviously, life insurance structured outside of the business owner's estate and sections of the Internal Revenue Code, like Section 6166, that extend the
David T. Leibell and Daniel L. Daniels, partners, Cummings & Lockwood LLC, Stamford, Conn.
One of the defining characteristics of closely held business owners is their need to control. This need prevents many from using lifetime transfer strategies, leaving only testamentary approaches, which are inherently less transfer tax efficient. Obviously, life insurance structured outside of the business owner's estate and sections of the Internal Revenue Code, like Section 6166, that extend the period to pay estate taxes can ease the burden on the next generation.
But there also are testamentary charitable strategies that can efficiently pass on the business. In the right circumstances, this kind of planning not only keeps the next generation of f...
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