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Chapter 14 Essentials: A Practitioner's Guide Through the Minefield

Product Code - TMW134
Speaker(s): Todd Angkatavanich, Withers LLP and Jonathan Blattmachr, Eagle River Advisors
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The provisions under Chapter 14 of the Internal Revenue Code have existed for over twenty years yet many of the draconian gift and estate tax provisions are not well understood by Trusts and Estates professionals.

This live webinar will provide a discussion of the many estate and gift tax pitfalls that practitioners need to keep in mind under these provisions whenever structuring transactions between family members. It will also include a broad overview of the statutory provisions of 2701 through 2704 and will also include discussions of the policy reasons behind the sometimes confounding rules included in Chapter 14.

Practical applications and the many pitfalls that practitioners need to keep in mind in connection with popular wealth planning techniques will be analyzed, including as well as:

  • GRATs, QPRTs and Sales of Remainder Interests
  • Section 2701 compliant Preferred Partnerships
  • "Vertical Slice" fund carried interest transfer planning and "Non-Vertical" alternatives
  • Sales to Intentionally Defective Grantor Trusts
  • Buy-Sell Agreements and Section 2703 challenges
  • FLP challenges under 2703 and other sections
  • Marital Deduction mis-match problems that can arise as a consequence of Section 2703 (as well as Section 2036)
  • Valuation provisions under Section 2704.

Educational Objectives

  • Obtain a "Big Picture" understanding of Pre-Chapter 14 law and what Chapter 14 was broadly intended to accomplish.
  • Understand the provisions of Sections 2701, 2703, 2703 and 2704 of the Code and their relative tax consequences.
  • Understand the policy reasons behind these provisions.
  • Understand where exceptions to these Code Sections exist and planning opportunities.
  • Highlight areas where the Chapter 14 "Red Flags" exist in connection with popular estate planning techniques.

Who Should Attend?
Trusts and Estates practitioners including lawyers, accountants, private bankers and financial planners.

Prerequisite: None
Level: Intermediate
Delivery method: Group live
Recommended CPE credit: 1.5 credits 

Todd Angkatavanich, Withers LLP and Jonathan Blattmachr, Eagle River Advisors

Todd Angkatavanich is a partner with Wither Bergman, LLP. He regularly advises domestic and international families and family offices with respect to creating trust and related business structures to preserve family wealth for multiple generations in a tax efficient manner with a particular emphasis on navigating the transfer tax pitfalls under Chapter 14 of the Code. A frequent author of articles, Todd is a member of the Editorial Advisory Board for Trusts & Estates Magazine and is also a member of the Advisory Board for BNA/Tax Management Estates, Gifts and Trusts Journal. Todd is a Co-Chair of the Business Investment Entities, Partnerships, LLC's and Corporations Committee of the American Bar Association, Real Property Trusts & Estates Section.

Jonathan Blattmachr is a Principal of Eagle River Advisors, a boutique advisory firm dedicated to developing and implementing innovative wealth and estate tax planning strategies on behalf of high net worth individuals and families. Mr. Blattmachr brings over 35 years of experience and recently retired as a Partner at Milbank Tweed Hadley & McCloy. The author or co-author of six books and over 500 professional articles, he is recognized as one of the country’s most creative lawyers on estate and trust taxation and charitable giving matters. Mr. Blattmachr graduated from Columbia University School of Law cum laude, where he was recognized as a Harlan Fiske Stone Scholar, and received his A.B. degree from Bucknell University, majoring in mathematics.