Proposed Regulations Under 2704 - How These Would Work, and What May Be Done Now for Clients and Structures

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Join experts John Porter and Stacy Eastland with moderator Alan Gassman for an informative and practical discussion on these new Proposed Regulations and related developments and insights.

In 60 minutes, the presenters will cover:
• Potential impact the proposed regulations have on the estate and gift taxation of family-owned entities.
• What types of entities are impacted?  
• What planning opportunities should not be affected by the proposed regulations? 
• The impact of the new test for "control". 
• "Disregarded Restrictions" and their impact.  
• The effect of the proposed rules regarding the lapse of liquidation rights and the three year contemplation of death rule.  
• The effect of proposed rules that would disregard small interests in an entity for purposes of determining ownership.  
• When will these regulations become final and will be the effective date?
• What is the likelihood these regulations will be challenged if finalized and how can we address the possibility of a successful challenge?  
• What should be done now while we still can?

Educational Objectives:

• Attendees will be able to develop an understanding of the impact the proposed regulations may have on planning if finalized in their current form. 
• Know what tools and techniques may still be used in "family entity planning" in light of the proposed regulations 
• Attendees will know what can be accomplished between now and the effective date of the final regulations.

Who would benefit most from attending this program?
Estate Gift and Tax Planners, Tax Attorneys, Estate Planners, Attorneys, Trust Officers, Accountants, Wealth Management Professionals, CPAs.

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S. Stacy Eastland , Managing Director, Goldman Sachs & Co

S. Stacy Eastland is a managing director of Goldman Sachs & Co. and is widely recognized as one of the nation’s leading authorities on estate planning for family businesses. He advises clients and their advisers on strategic wealth management plans, combining a variety of federal income tax, estate planning and gifting techniques. Prior to joining Goldman Sachs, Mr. Eastland was a senior partner in the law firm of Baker Botts, LLP, in Houston.

Mr. Eastland is listed in “Who's Who in America” and “The Best Lawyers in America.” He has also been listed in Town & Country and in Bloomberg Personal Finance as one of the top trust and estate lawyers in the U.S. Articles about Mr. Eastland’s estate planning ideas have been featured in Forbes and Fortune magazines.

A frequent lecturer on estate planning topics nationwide, Mr. Eastland is a Member of the International Academy of Estate and Trust Law and a Fellow of the American College of Trust and Estate Counsel (Regent for 1992/1998 term). He received his B.S. (with Honors) from Washington and Lee and his J.D. from The University of Texas (with Honors). 

John Porter , Senior Partner, Baker Botts LLP

John Porter is a Senior Partner and Partner-In-Charge of the Houston Office who handles federal gift, estate and income tax litigation and controversy work. He is nationally recognized for his expertise in representing taxpayers before and against the Internal Revenue Service in estate and gift tax controversies, especially those involving hard-to-value assets such as interests in family limited partnerships and limited liability companies.

Mr. Porter has served as lead counsel for taxpayers in numerous cases in the United States Tax Court, the Court of Federal Claims, United States District Courts and Courts of Appeals. He also has represented taxpayers in numerous other federal tax audits and administrative appeals. He frequently advises and represents fiduciaries and beneficiaries of trusts and estates with respect to administration and fiduciary duty issues.

Mr. Porter is a Fellow and a former Regent of the American College of Trust and Estate Counsel.  He is also the former chair of the Tax Litigation and Controversy Section of the American Bar Association's Real Property, Probate & Trust Section.  John earned a B.B.A. in accounting from Texas A&M and a J.D. from Baylor University Law School.

Alan Gassman (Moderator) , Founder , Gassman, Crotty & Denicolo

Alan Gassman (moderator) is founder of the Florida-based law firm of Gassman, Crotty & Denicolo, and principal architect of the Practical and Essential Estate Gift and Trust webinars of which this program is a part.