PFP2524. How to Handle Entity Redemption Plans Funded with Life Insurance in Light of the Connelly Supreme Court Decision

We will discuss the significance of buy-sell agreements in business succession planning, including the impact of the recent Supreme Court decision in Connelly v. United States. All buy-sell agreements and insurance premiums should be reviewed. Specific guidance will be presented for professional entities, including CPAs and attorneys. The recent Clark Raymond decision will also be discussed.

Session highlights include:
• Proper structure post-Connelly
• Entity considerations—corporation v. partnership
• Contract purchase price allocations
• Special S corporation traps
• Section 754 election and partnership traps
• Goodwill and valuation

Learning Objectives:

• Determine the tax effects of buy-sell agreements.
• Identify key concepts of business valuation and life insurance.