Bullet Proofing LLCs and FLPs (PDF PPT ONLY)

Speakers: John Porter

Year: 2011



The IRS frequently raises challenges to closely held entities in a transfer tax context, including disputes regarding gift on formation/indirect gift, step transaction, annual exclusion gifts, Section 2036, valuation issues and formula transfers. This session will explore these situations, and also will review the use of life insurance in connection with closely held entity planning, including the use of Graegin notes to secure liquidity to pay federal estate tax.

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