Family Limited Partnerships - Where We've Been Where We're Going

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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 recorded 90-minute webinar, our experts 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. This is a recorded webinar that originally ran live on August 30, 2012. As an eLearning course, you must pass the final exam of this course to receive CPE credit.

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



N. Todd Angkatavanich is a principal at Withers Bergman, LLP. His 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 trusts and related business structures to preserve, protect and grow family wealth for multiple generations in a tax efficient manner. 

A frequent speaker, Todd has given presentations and webinars/teleconferences for various organizations including the Heckerling Estate Planning Institute, the American Bar Association Real Property, Trusts & Estates Law Section, Trusts & Estates magazine, BNA/Tax Management, as well as numerous Estate Planning Councils, CPA societies, Family Office associations and other organizations. Todd has authored numerous articles in publications such as Trusts & Estates, Estate Planning, ACTEC Journal, BNA/Tax Management Estates, Gifts and Trusts Journal, Private Wealth, Private Asset Management, FFI Practitioner and other publications. Todd is a member of the Editorial Advisory Board of Trusts & Estates magazine (Estate Planning and Taxation Committee). He is also a member of the Advisory Board for BNA/Tax Management Estates, Gifts and Trusts Journal. Todd is the 2012 recipient of the Best Private Client Lawyer Award by Family Office Review North America. 

Todd is the Vice Chair of the Business Planning Group – Business Investment Entities Committee of the American Bar Association, Real Property, Trusts & Estate Law Section for 2012-2013. 

Todd received his B.A., in Economics, magna cum laude from Fairleigh Dickinson University, his J.D., Tax Law Honors, from Rutgers School of Law, his M.B.A. from Rutgers Graduate School of Management, and his LL.M, in Taxation, from New York University School of Law. Todd may be contacted at todd.angkatavanich@withers.us.com.


Edward A. Renn is a principal in the international law firm, Withers Bergman LLP. Ed focuses on domestic and international private client matters. He provides legal advice on U.S. and international estate planning, income maximization strategies, FLP and LLC planning, wealth preservation, business succession planning, international tax planning for entities and individuals, planning for same-sex couples, trust structures and estate administration. Ed frequently utilizes sophisticated life insurance strategies in both income and transfer tax planning. Ed is a frequent speaker and writer, and has co-authored several books on estate planning: Protecting the Family Fortune: Advanced Planning for Ultra-High-Net-Worth Family Businesses and Their Owners; Fortune’s Fortress – A Primer on Wealth Preservation for Hedge Fund Principals; and Advanced Estate Planning – Wealth Preservation for Physicians. You can contact Ed at edward.renn@withers.us.com.