eLearning

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

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DESCRIPTION

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 practical course 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:
• 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 §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 §2036)
• Valuation provisions under §2704

Educational Objectives
• Apply the provisions of Chapter 14 provisions and review their relative tax consequences
• Distinguish the characteristics among the provisions under Chapter 14
• Sort out the policy reasons behind Chapter 14 provisions
• Recognize the kinds of transactions that may result under the application of Chapter 14
• Identify exceptions to the various Chapter 14 code sections and find planning opportunities under such provisions
• Identify situations that trigger the “zero valuation rule,” as well as its exceptions
• Recall estate tax results of a grantor’s estate upon its death

SPEAKERS

TODD ANGKATAVANICH , WITHER BERGMAN, LLP

Todd Angkatavanich is a partner with Wither Bergman, LLP.  He regularly advises domestic and international families 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 , EAGLE RIVER ADVISORS

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.