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Strangi II Where From Here?Strangi II Where From Here?

The Tax Court's second opinion in the now famous Estate of Strangi v. Commissioner (Strangi II)1 sent shockwaves throughout the estate-planning profession and created new stumbling blocks for practitioners who create family limited investment partnerships or family limited liability companies (FLPs). While the decision addresses the application of both Internal Revenue Code Sections 2036(a)(1) and

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Roy M. Adams, partner, and N. Todd Angkatavanich, associate, Sonnenschein Nath & Rosenthal LLP, N

The Tax Court's second opinion in the now famous Estate of Strangi v. Commissioner (Strangi II)1 sent shockwaves throughout the estate-planning profession and created new stumbling blocks for practitioners who create family limited investment partnerships or family limited liability companies (FLPs). While the decision addresses the application of both Internal Revenue Code Sections 2036(a)(1) and 2036(a)(2) to an FLP to cause the assets transferred to an FLP to be included in a taxpayer's gross estate, it is the application of Section 2036(a)(2) that is prompting trusts and estates professionals to revisit the structure of both new and exist...

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About the Authors

Roy M. Adams

Senior Chairman of the Trusts & Estates Practice Group, Sonnenschein Nath & Rosenthal LLP

Roy M. Adams (1940 - 2014)

 

Roy M. Adams is Senior Chairman of the Trusts & Estates Practice Group at the national law firm of Sonnenschein Nath & Rosenthal LLP, which has offices in Chicago, IL, New York City, NY, Short Hills, NJ, Los Angeles, CA, San Francisco, CA, Washington, DC, St. Louis, MO, Kansas City, MO, West Palm Beach, FL and Phoenix, AZ. Mr. Adams has previously been Co-Chair of the Trusts & Estates Practice Group at Schiff Hardin & Waite and Worldwide Head of the Trusts and Estates Practice Group at Kirkland & Ellis LLP.

Mr. Adams conducts an extensive national and international practice in the areas of estate and tax planning and administration, advising individuals and major families on wealth transfer techniques at Federal and state levels and private foundations and public charities. He lectures nationally and internationally and is a greatly sought-after speaker. He has frequently and successfully served as an expert witness, defending lawyers, accountants, banks and others who have been improperly accused of wrongdoing. He is admitted to practice in the states of New York and Illinois.

Mr. Adams is Professor Emeritus of Estate Planning and Taxation at Northwestern University School of Law where, for over 25 years, he has taught estate planning and taxation. He has received Northwestern University's Alumni Merit Award for his outstanding professional achievements. Mr. Adams also serves as a member of the Tax Advisory Boards of the Museum of Modern Art and of Lincoln Center for the Performing Arts, both in New York City.

Mr. Adams is a member of the distinguished teaching faculty of Cannon Financial Institute, and is also a Senior Consultant to Cannon's management. He contributes extensively to internet publications through a joint venture with Cannon, and leads special professional education seminars and monthly telephone conferences, as well as web-casts and satellite broadcasts, on sophisticated but practical estate, trust and business succession planning and administration topics.

Mr. Adams is a Fellow of the American College of Trusts and Estates Counsel and is listed in "Best Lawyers in America." He has received high national recognition by Chambers USA in the practice area of Wealth Management and Trusts & Estates and is further acclaimed as a "New York Super Lawyer." Mr. Adams has been conferred "Best Lawyer" status by The American Lawyer. He is Special Consultant to Trusts & Estates Magazine, for which he writes a bimonthly column as well as a highly acclaimed quarterly column on tax fundamentals. He often contributes a column on estate planning, designed for the brokerage community, to Registered Representative Magazine, and articles on estate planning to Financial Advisor Magazine. His newest book, 21st Century Estate Planning: Practical Applications, was first published by Cannon Financial Institute in 2002, is revised each year, and has received great acclaim, particularly for its innovation, creativity and practical advice. The 2006 Edition has also been well received.

Mr. Adams has authored a two-volume text, Illinois Estate Planning, Will Drafting and Estate Administration, and has been a Contributing Editor toUnderstanding Living Trusts. Another of his popular publications is entitledWit & Wisdom – the Best of Roy Adams.

N. Todd Angkatavanich

Principal, National Tax Department, Ernst & Young LLP, Private Client Services Group

N. Todd Angkatavanich is a principal in the National Tax Department of Ernst & Young LLP, in the Private Client Services Group. His practice is focused on tax, trusts and estates, and business succession matters for affluent individuals and their families. He regularly advises domestic and international families and family offices with respect to creating trust and related business structures to preserve, protect and grow family wealth for multiple generations in a tax efficient manner. 

Todd has been published in Trusts and Estates, Private Wealth and Estate Planning Magazine, ACTEC Journal, BNA Tax Management, Private Asset Management and other publications.  He is a member of the Editorial Board for Trusts & Estates Magazine.  He is also a member of the Advisory Board for BNA/Tax Management Estates, Gifts and Trusts Journal. 

Todd is a frequent speaker on estate planning topics such as Family Limited Partnerships, Business Succession Planning and related Chapter 14 issues.  He has given presentations, webinars and teleconferences for various organizations including the Heckerling Estate Planning Institute, the ABA Section of Real Property Trust & Estate Law Spring Symposia, Trusts & Estate Magazine, BNA/Tax Management as well as numerous estate planning councils, CPA Societies and professional organizations.  Todd has been quoted in articles that have appeared in Barron's, Bloomberg Businessweek, The Boston Globe, The Miami Herald, MSN Money and other publications.

Todd is the recipient of the 2012 "Private Client Lawyer of the Year" Award, FOR (Family Office Review) Awards, North America, Chicago.

Todd is a vice-chair of the Business Planning Group - Business Investment Entities Committee of the American Bar Association, Real Property, Trust & Estate Law Section.