SOP2403. Estate Planning for the .1%

TO BE TOP .1% IN 2023, A HOUSEHOLD NEEDED A NET WORTH OF $61,827,166. HOW DOES PLANNING FOR THOSE WITH $62M AND ABOVE DIFFER FROM CLIENTS WITH LESSER WEALTH? THE RECIPROCAL TRUST DOCTRINE, DAPTS, HYBRID-DAPTS, OR SPAT SHOULD NOT BE NECESSARY. OR SHOULD THEY BE? WHAT TYPES OF PLANNING TECHNIQUES SHOULD BE CONSIDERED? HOW CAN, FOR EXAMPLE, PLANNING USING A TECHNIQUE LIKE A NOTE SALE TRANSACTION BE ENHANCED TO POTENTIALLY PROVIDE A GREATER CHANCE OF SUCCESS AND TO BETTER DEFLECT AN AUDIT CHALLENGE? STEPS LIKE INDEPENDENT COUNSEL, ESCROW ARRANGEMENTS, AND ALTERNATE TECHNIQUES FOR EACH TRANSACTION (E.G., USE A DIFFERENT SPILLOVER RECEPTACLE IN EACH TRANSACTION). HOW CAN CLIENTS WITH SCORES OF ENTITIES MORE PRACTICALLY HANDLE DOCUMENTATION? HOW TO ADDRESS POWELL/MOORE ISSUES THAT A WANDRY OR CHRISTIANSEN DEFINED VALUE MECHANISM MIGHT INTRODUCE. DISCLAIMER PROVISIONS IN TRUSTS, SPILLOVER TO SUB-TRUSTS FOR THE GRANTOR AND MORE. INCOME TAX PLANNING FOR NON-GRANTOR COMPLEX TRUSTS. WHAT MIGHT CCA 202353018 MEAN TO A CLIENT’S RENUNCIATION OF A DAPT OR HYBRID-DAPT INTEREST? THE IMPACT OF TAX PROPOSALS LIKE THE AMERICAN HOUSING AND ECONOMIC MOBILITY ACT OF 2024 COULD BE ESPECIALLY DEVASTATING. AND MORE…

Learning Objectives:

• Identify how larger wealth transactions can be handled with more sophisticated techniques that may enhance the plan’s potential for success.
• Apply variations of planning techniques into components of a complex large estate transfer.
• Use one planning approach to address state pass-through business alternative income tax (BAIT)/pass-through entity tax (PTET) programs, Powell, and estate inclusion.
• Identify techniques to consider incorporating into complex trust plans.
• Use one planning approach to address state pass-through business alternative income tax (BAIT)/pass-through entity tax (PTET) programs, Powell, and estate inclusion.