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OVERVIEW

EXPERIENCE

Experience

Establish Charitable Remainder Trusts

Advised clients on and implemented structured charitable remainder trusts to achieve asset diversification for clients with low basis marketable securities.

Counsel To Nonprofit Organizations

Assist individuals and groups in the formation of charitable organizations and advise existing charitable organizations on a variety of legal and tax matters.

Form Private Foundations And Charitable Trusts

Assisted clients in establishing private foundations or charitable trusts to hold family assets. These include endowment agreements with various educational or charitable institutions. We also provided ongoing family foundation counseling and grant making consultation and advice.

Estate Planning Documents In Context Of Family Dynamics

Assisting clients in the preparation of their wills, trusts, powers of attorneys and healthcare documents with an eye to internal family dynamics and the family members' abilities to handle fiduciary and business decisions. This process often includes consideration as to whether non-family executors and trustees may benefit the estate or trust administration. These documents include: revocable living trusts for lifetime management of assets or out-of-state real property to avoid probate, as well as durable powers of attorney for financial and healthcare decisions, Durable Powers of Attorney (DPA), healthcare directives and living wills, Health Insurance Portability and Accountability Act (HIPAA) authorizations for release of protected healthcare information, and premarital and postnuptial property status agreements that clarify status of community and separate property.

Estate Planning And Investing

Advised client on the use of family partnerships and limited liability companies to hold vested non-statutory stock options in Fortune 500 companies for estate planning, investment and management purposes.

Gift Planning

Providing advice on tax efficient gifting to children and grandchildren, including drafting and implementing "Crummey" Trusts, Generation-Skipping Trusts, Residence Trusts (QPRTs), Grantor Retained Annuity Trusts (GRATs) and Irrevocable Life Insurance Trusts (ILITs). We also assisted clients with education savings planning, including tax effects of 529 Plans, and provided advice on tax efficient giving to charities, including Charitable Lead Trusts and Charitable Remainder Trusts (CLATs, CLUTs, CRATs and CRUTs). In addition, we prepared estate and gift tax forecasts and plans for payment of estate taxes for business succession.

Multi-Generational Estate And Asset Planning

Advising clients on multi-generational estate and asset planning of families owning large operating businesses.

Estate Distribution

Advised on post-mortem establishment of a timber management company to facilitate estate distribution and qualification for deferral of estate tax payments.

Guardianship And Special Needs Trust

Represent trustees of special needs trusts and guardians of loved ones in the preparation of periodic court reporting obligations. We also work with individuals seeking to become guardians of loved ones who have lost the capacity to manage their affairs.

Trust And Estate Mediation

Representing clients in the negotiation of mediated agreements covering a wide variety of trust and estate disputes.

Probate And Trust Administration

Advising clients on estate and trust administration, probate, estate and trust dispute resolution matters and the preparation of gift and estate tax returns.

Creation Of Private Foundations

Created private foundations to hold family assets, including family foundation counseling and grant-making consultation and advice.

Tax And Estate Planning For Family Office

Provide ongoing consultation with an active, multifunctional family office on a wide range of tax, estate planning and administrative matters.

Limited Liability Companies And Family Limited Partnerships

Established limited liability companies (LLCs) and family limited partnerships (FLPs) for the management of family real estate and other assets among multiple generations of the same family.

Maintaining The Privacy Of Recognizable Individuals

Working with well-known clients and families to develop and implement a variety of strategies, including title-holding and fictitious name trusts, to enable them to buy, sell and hold real estate and other assets without the risk of being identified and located through searchable public records.

Administering Large Global Estate

Advising in a matter involving a client who died leaving a large estate for us to administer for the benefit of family members as well as charities around the world. Although the estate is entitled to marital and charitable deductions, a majority of the estate is subject to federal estate taxes. Given the uncertainty in the stock market, we have worked closely with the executor and trustee to liquidate and preserve the assets in order to fund the specific bequests and tax obligations. The estate owns a residence and extensive real estate on a remote island. Maintaining and marketing the properties has presented various legal challenges given the uniqueness of the property and the current real estate market. The decedent also had ownership interests in entities, which required special attention due to varying interests of the other owners and beneficiaries.  We continue to address complex legal issues as we work with international beneficiaries to unwind entities, satisfy tax liabilities, liquidate and preserve the assets of the estate.

International Tax Planning

Working with many clients on international tax planning, such as representing a Belgian client currently living in Mexico with tax issues associated with his work in the U.S.

Estate Tax Evaluation Disputes

Provided counseling and managed the favorable resolution of the estate tax liability in a complex estate involving multiple lawyers, experts and a corporation with international subsidiaries. The IRS obtained its own independent valuation of the corporation. The resolution involved extensive negotiations with the IRS and critical analysis of the experts' valuations.

IRS Private Letter Ruling

Determined that changes to articles of incorporation did not affect grandfathered status of buy-sell provisions contained in the articles of incorporation for federal gift tax and generation skipping tax purposes.

IRS Private Letter Ruling

Formed a trust by state, which authorized that a binding agreement does not result in a gift under IRS Code 2511.

IRS Private Letter Ruling

Advised on a Technical Advice Memorandum on transfers of limited partnership units to family members as gifts eligible for annual gift tax exclusion.

IRS Private Letter Ruling

Obtained approval on structure of complex grantor retained annuity trusts (GRATs) with revocable spousal annuities.

IRS Private Letter Rulings Regarding Generation-Skipping Tax

Obtained favorable Private Letter Rulings from the IRS regarding the generation-skipping tax exemption.

Gift Tax Representation

Preparing gift tax returns to report taxable gifts and federal and Washington estate tax returns and represented taxpayers on estate and gift tax audits.

IRS Private Letter Ruling

Determined that changes to articles of incorporation did not affect the grandfathered status of buy-sell provisions contained in the articles of incorporation for federal gift tax and generation-skipping tax purposes.

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