Private equity is a hot investment these days. And while you may be referring your ultra-high-net-worth clients to established private equity firms, don't be surprised if a wealthy client asks you for advice on a private investment opportunity...
Google Estate of Lillie Rosen and you'll get about 20,200 results. The number and breadth of websites devoted to Lillie Rosen and her family limited partnership (FLP) shows the buzz this case generated in the estate-planning community this year...
Advisors promote trusts as an indispensable component of the estate plan. We tout the importance of trusts for credit shelter and generation-skipping transfer (GST) tax planning. We proclaim that trusts protect assets from creditors, including...
Andrew M. Katzenstein, a partner in the Los Angeles office of Katten Muchin Rosenman LLP, reports: Changes proposed to regulations (Treasury Regulations Sections 1.72 and 1.1001-1(j)) governing the income taxation of private annuity sales...
In recent years, asset protection planning has won its rightful place as a legitimate specialty, aimed at curtailing the reach of potential, future creditors. Of course, there are still those who believe that it's wrong to ensure against the...
Although the grantor retained annuity trust (GRAT) is an excellent estate-planning technique, it can be complicated to create, depending upon the client and assets involved. Hard-to-move assets can mean problems. Questions about when the GRAT is...
Offshore planning has gotten a lot of bad press lately.1 It's getting slammed in the U.S. Senate. This August, a Senate subcommittee held a week-long hearing on its report, Tax Haven Abuses: The Enablers, the Tools and Secrecy2 that purported to...
In The Curmudgeon's Guide To Practicing Law, author Mark Herrmann points out that You cannot answer a legal question without knowing the context in which it is posed. You must therefore be sure to understand the context of all the work that you...
Perhaps no estate-planning tool is more subject to the law of unintended consequences than the ubiquitous Crummey1 power. But, although there can be estate, gift and generation-skipping transfer (GST) tax consequences, it's the income tax impact...
There's some good news in the ongoing war with the Internal Revenue Service over family limited partnership (FLP) discounts: IRS agents are settling practically all of the cases and even most of the ones. That means it pays to know how to...
