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Tax Management Portfolio, Estate Planning for Corporate Executives, No. 808-4th, deals with typical problems arising in wealth transfer planning for corporate executives. A lack of liquidity and concentration of investments in the employer's stock (particularly if the employer is a closely held corporation) may present special planning and administration problems for executives and their fiduciaries. In addressing liquidity concerns, this Portfolio discusses the tax consequences of the use of life insurance in general, and the continued viability of split-dollar life insurance arrangements for gift and estate tax purposes.
This Portfolio discusses the relevance of standard estate planning techniques (e.g., inter vivos gifts and trusts, life insurance and life insurance trusts, and the use of the marital gift and estate tax deductions) to the special problems of corporate executives. The drafting of will and trust instruments (particularly fiduciary powers) to provide sufficient flexibility to meet the liquidity needs of the estates and beneficiaries of the executives, are discussed.
In addition, planning for corporate executives requires extensive knowledge of planning techniques relating to executive compensation plans. This Portfolio, therefore, examines nonqualified deferred compensation (NQDC) plans and nonqualified stock options. With respect to NQDC, this Portfolio discusses how §409A and the related regulations and IRS Notices impact the structure of these plans and in particular, the treatment of death benefits under these plans. This Portfolio also discusses planning for qualified pension and profit-sharing plans and qualified stock options, but the discussion of those arrangements is limited and further reference should be made to the Compensation Planning Portfolios in the U.S. Income Series, as well as 814 T.M., Estate and Gift Tax Issues for Employee Benefit Plans.
In regards to the special concerns of owners of closely-held businesses, this Portfolio considers buy-sell agreements and the opportunities to pay an estate tax liability in installments. In regards to closely held businesses, further reference may be made to 809 T.M., Estate Planning for Owners of Closely Held Business Interests.
This Portfolio may be cited as Drennan, Goldstein, and Erblich, 808-4th T.M., Estate Planning for Corporate Executives.
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