Forms of close-held business organizations: sole proprietor, general partnership, limited partnership, limited liability partnership, limited liability company, corporation; fragmentation of financial interests among business organizations, intra-family sales and leasebacks, market rate intra-family loans, third party guarantees, financing arrangements, independent contractor status, leased employees, common law employees, family member roles, combinations of business organizations, value deflection opportunities, controlled group, affiliated service group and multiple employer groups.
Our experience and foresight have led to significant gains.
IRA distributions to qualified charities, bargain sale, gift annuity, annuity and endowment contracts, remainder interests in personal residence, qualified conservation contributions, charitable partial interest transfers, charitable lead trust, charitable remainder trust, donor advised fund and private foundation.
Non-qualified plans of deferred compensation, Rabbi trusts, top hat and excess benefit plans, funding and coordination with tax-qualified plan limits; tax qualified plans of deferred compensation: defined contribution: SEP/IRA, SIMPLE, 401(k), Roth characterizations, profit sharing, allocation formulas, cross testing; stock bonus, ESOP, money purchase, target benefit; defined benefit: flat benefit, fixed benefit, unit benefit, permitted disparity, integration with Social Security, floor offset plans, cash balance and other hybrid plans; health and welfare plans, group term life insurance, educational assistance programs, dependent care assistance programs, adoption assistance programs, cafeteria plans, flexible spending arrangements, qualified transportation fringe benefit arrangements.
Family Lifetime Gifts
Commercial annuity, joint and survivor life insurance, outright fractional interest gifts, net gift, Crummey life insurance trusts, intentionally tax defective trusts, family residence trusts; intra-family sale/leaseback or gift/leaseback, installment sale, self-canceling installment note, reduced interest rate loan and third party guaranty, private annuity, joint or split property purchase, remainder interest sale, grantor retained annuity and unitrust, fractional interest real estate “sliver” gifts; cost basis determination, comparison of lifetime vs. testamentary gifts, carry-over basis v. date-of-death or alternate valuation date increase in cost basis; preparation and filing of gift tax returns.
Term, ordinary, endowment and universal life insurance products, incidents of ownership, irrevocable life insurance trust agreements, corporate-owned life insurance, split-dollar arrangement, key person insurance, cross-purchase/redemption insurance, partnership-owned life insurance, group term life insurance, application of transfer for value rule, investor-owned life insurance; review product design, hidden costs, assessing guarantees, illustrations, guaranteed values vs. projected values, evaluation of policy performance, present value of outlay, internal rate of return on cash value, internal rate of return at death.
Administration process, income and estate tax elections, renunciation, surviving spouse award, full or partial disclaimers, IRA distributions, potential second or third generation distributions, partial or full Roth IRA characterization, estate liquidity options, corporate stock redemption, deferred tax payment plans, reversions and remainders; valuation considerations, coordination of value of non-marketable assets, fractional interest, minority and marketability discounts, cost basis step-up computations as to capital assets, alternate valuation date, use of portability in respect of basic exclusion amount, preparation and filing of Federal and state estate tax returns and coordination with family accountant as to appropriate filings of Federal and state income tax returns.
Payable on death arrangements, transfer on death instrument, funding of revocable trust, QTIP/marital deduction, generation-skipping trust, directed Illinois or Delaware trust, administrative trustee, distribution advisor, investment advisor, special asset advisor and trust protector, Powers of Attorney for Property and Health Care and IRA distribution trust.