Ultra-high net worth client’s estate plan left vast sums to trusts for children, with little likelihood they would ever need much of the money. Client was receptive to the idea of creating charitable gift annuities for the children, to provide a lifetime stream of distributions, with relatively small discretionary trusts as a backstop. The resulting plan saved the client substantial estate taxes and provided amply for the children.
Converted private, perpetual foundation to spend-down, allowing the client more control over governance and avoiding mission shift.
Successfully implemented sophisticated wealth transfer techniques including self-cancelling installment note (SCIN), initially removing over $5 million n value from the client’s estate. Over time, the amount removed from the taxable estate has increased many times, due to appreciation.
Effectively employed postmortem planning techniques and obtained favorable IRS Private Letter Ruling, to reverse effects of poor planning by decedent’s attorney, saving over the client $300,000 in estate taxes.
Recommended and implemented reallocation of personal injury award between decedent’s estate and family members, saving family members over $250,000 in estate taxes.
Implemented charitable trust for client owning a large concentration of highly appreciated publicly-traded stock, permitting him to diversify his holding into mutual funds without triggering capital gains, significantly increase his lifetime income, and receive charitable income tax deduction.