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 thereunder 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:
Educational Objectives:
Who Should Attend? Trusts and Estates practitioners including lawyers, accountants, private bankers and financial planners.
Todd Angkatavanich, Esq., Partner, and Peter Slater, Esq., Withers Bergman
Todd Angkatavanich’s 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 significant experience working with clients to structure US and international wealth preservation vehicles such as Family Limited Partnerships, Grantor Retained Annuity Trusts, Sales to Intentionally "Defective" Grantor Trusts, Foreign Grantor Trusts, Qualified Personal Residence Trusts, Buy-Sell Agreements and Preferred Freeze Partnerships. He also advises clients on business succession matters, with a particular emphasis on navigating the various tax pitfalls under Chapter 14 of the Code. In addition, Todd's practice also involves the preparation of estate planning documents for clients including "tax-sensitive" Wills and Revocable Trusts, Generation-SkippingDynasty Trusts and Irrevocable Life Insurance Trusts. Todd also has experience in advising Hedge Fund and Private Equity Fund professionals with respect to transferring carried interests into multi-generational trusts for the benefit of younger family members in a tax-efficient manner.Todd is a frequent contributor to Trusts and Estates and Private Wealth magazines. He has also been published in 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.Peter Slater is Special Counsel to the law firm of Withers Bergman in New York.Peter's practice focuses on protecting & enhancing individual, family & business wealth through: planning to minimize income and estate taxes (U.S. international); estate planning; charitable, marital and succession planning; business structuring and transactions; trusts and estates (administration-disputes-drafting); and creditor protection planning. Peter also has a sub-specialty in business and general aviation law, including aviation regulatory and tax matters. He has experience in the areas of the purchase, sale, leasing, financing and management of corporate aircraft (including domestic and foreign registration) and related insurance, regulatory and federal and state tax issues, including tax treatment of personal versus business use of aircraft, capitalization or expense of maintenance, depreciation, and passive activity loss limitations.Peter is co-author of "Late Payment of Legacies: After Seven Months Things Can Get Interesting," NYSBA Trusts and Estate Law Section Newsletter; and contributions to "Going Non-Vertical with Fund Interests -- Creative Carried Interest Transfer Planning When The "Vertical Slice" Won't "Cut It," Trusts and Estates Magazine, November 2010.