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


Product Code - TMW15
Speaker(s): N. Todd Angkatavanich, Esq. and Edward A. Renn, Esq., WithersBergman, LLP
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 FLPs 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 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 FLP 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 FLP planning, which will include a discussion of the various arguments that have been raised, both successfully and unsuccessfully, by the IRS over the years in its ongoing challenge of FLPs as well as practical tips for properly administering FLPs.

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
  • FLP planning with Sales to Grantor Trusts
  • What you should learn from this webinar:
  • Big picture understanding of FLP planning and theories behind IRS challenges
  • Practical tips for properly administering an FLP
  • Consequences of inclusion under Section 2036 or application of Section 2703
  • Future arguments against FLPs

Who should attend:

Attorneys, CPAs, financial planners, family office professionals

N. Todd Angkatavanich, Esq. and Edward A. Renn, Esq., WithersBergman, LLP

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.

Ed Renn, a partner with Withers Bergman LLP, focuses on domestic and international private client matters. He provides legal advice on US and international estate planning, income maximization strategies, FLP and LLC planning, wealth preservation, business succession planning, international tax planning for entities and individuals, trust structures and estate administration.

A significant part of his practice focuses on domestic and international estate planning for hedge fund and private equity principals. Ed is a frequent speaker and has co-authored several books on estate planning for individuals.