Where Have All the Large Cases Gone?

Speakers: Michael Amoia

Year: 2016



Historically, many large cases focused on providing cash for estate taxes. However, changes in the estate and gift tax rules have dramatically altered the "need" for funding this obligation. This has impacted all professions:  lawyers do not have as many documents to draft, accountants have fewer complex tax returns to prepare and CFOs are less concerned about liquidity. So, where does this leave you and your opportunity for large cases? In short, they are still out there - just under different rocks, due to concentrated stock positions, negative basis real estate, qualified money and other hard-to-transfer assets. We will cover current transfer tax rules, recent changes issued by Treasury and the IRS and the opportunities created by these rules, the impact of low interest rates and how to position various "mortality bonds" (a.k.a. life insurance) in the sales process. Further, because so many other professionals don't understand how to pay premiums without triggering gift taxes, we will highlight key strategies that you can bring to the table: private loans, split dollar, asset swaps, premium financing and other techniques to leverage the transactions. All topics discussed are from real cases that resulted in real sales.

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