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Family Limited Partnerships – Where We’ve Been, Where We’re Going


Product Code - TMW41
Speaker(s): Todd Angkatavanich, Esq., Partner, WithersBergman LLP and Stephanie Loomis-Price, Shareholder, Winstead PC
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Family Limited Partnerships have been popular estate planning vehicles for decades due to both the tax and non-tax advantages that these vehicles can offer. As estate planning professionals are well aware, these vehicles can be subject to scrutiny by the IRS and have been challenged under a number of different theories over the past two decades.

Case law has demonstrated that, if properly structured, these entities can be very useful vehicles, however, case law has also made abundantly clear that, if not properly structured and administered, negative tax consequences can result. The landscape in the partnership area is continuously evolving, and it is critical for any practitioner who plans with these vehicles to be well aware of developments in this area.

In this 90-minute webinar, our experts will discuss the history of partnership planning, discussing various arguments that have been raised, both successfully and unsuccessfully, by the IRS over the years in its ongoing challenge of partnerships. Our speakers will also discuss practical tips for properly administering family limited partnerships.

Topics to be covered in include:

  • Indirect gift
  • Gift on formation
  • Step transaction
  • Challenges under IRC Section 2036(a)(1) and (a)(2)
  • Challenges under IRC Section 2703
  • Marital deduction mis-match issues
  • Partnership planning with Sales to Grantor Trusts
  • Best practices in administering family limited partnerships

Who should attend:

Attorneys, CPAs, financial planners, family office professionals

Educational Objectives

  • Gain a historical perspective across the history of family limited partnerships – including landmark cases
  • Understand the evolution of partnerships and their impact in recent and current arguments such as the indirect gift theory and the step transaction doctrine
  • Know the theories supporting IRS challenges
  • Gain practical tips for partnership administration
  • Know the consequences of failing under Section 2036 and Section 2703 

Todd Angkatavanich, Esq., Partner, WithersBergman LLP and Stephanie Loomis-Price, Shareholder, Winstead PC

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-Skipping Dynasty 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 the Bloomberg BNA Estates, Gifts and Trusts Advisory Board.

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, Bloomberg BNA, as well as numerous estate planning councils, CPA societies, and professional organizations.

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

Stephanie Loomis-Price handles federal gift and estate tax litigation against the Internal Revenue Service, as well as state fiduciary and probate controversy work. She has assisted clients in numerous cases in the United States Tax Court, the United States Court of Federal Claims, and the United States Court of Appeals for the Fifth, Eighth, and Eleventh Circuits, as well as County Probate Courts across Texas. She also counsels clients regarding complex estate administration. Stephanie currently serves on Council for the Real Property, Trusts and Estates Law Section of the American Bar Association, as well as Co-Chair of the Continuing Legal Education Committee of the same organization.

Board Certified in Estate Planning and Probate Law, Stephanie is a Fellow of the American College of Trust and Estate Counsel (ACTEC).

While her cases have included numerous challenging fiduciary litigation matters involving trustees, beneficiaries and grantors, her involvement in such litigation has increased markedly in recent years, resulting in Winstead’s formation of the Fiduciary Litigation Practice Group, which Stephanie co-chairs.
Stephanie is a frequent speaker across the country, speaking in the past year at many of the premier estate planning conferences, such as: Heckerling Institute on Estate Planning; ACTEC; the Hawaii Tax Institute; the Tulane Tax Institute; the Washington State Bar Association Annual Estate Planning Seminar; American Bar Association Business Law Section; IMCA Advanced Wealth Conference; Texas Society of CPAs Annual Advanced Estate Planning Conference; ALI CLE Estate Planning for Business Owners Course; Skills Training for Estate Planners Course; ALI CLE Planning Techniques for Large Estates; and ALI CLE Advanced Estate Planning Techniques.

She has been recognized in The Best Lawyers in America publication and as a Texas Super Lawyer by Texas Monthly. She is a past recipient of the Excellence in Writing Award by Probate & Property and the Judge Thomas Gibbs Gee Award for Outstanding Pro Bono Service.