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Home >
Taxation > Best Family Limited Partnership Planning Ideas |
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Prerequisite
Overview of Federal Income Taxation
Knowledge Level
Intermediate
Copyright
2008
Publication Date
December, 2008
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| Introduction |
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Organization |
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Learning Objectives |
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Author Bios |
| Title: |
Best Family Limited Partnership Planning Ideas (in cooperation with the Tulane Law School 57th Annual Institute on Federal Taxation) |
| Prerequisite: |
Overview of Federal Income Taxation or comparable knowledge/experience |
| Advance Preparation: |
None |
| Knowledge Level: |
Intermediate |
| Subject Matter Area: |
Taxes |
| Date of Publication: |
December 2008 |
| Copyright © |
2008 by Bisk Education, Inc. All rights reserved. |
| Recommended CPE Credits: |
5 QAS/Registry (50-minute hour) |
| Expiration Date: |
One year from date of receipt to complete program and submit quizzer to obtain credit |
| Passing Grade for Quizzer: |
70 percent or higher |
One of the many benefits of the author's job is that he gets to see some outstanding family partnership planning ideas by practitioners. One of the other benefits of his job is that he gets to work with some outstanding practitioners in his group, who have helped him with certain ideas presented in this program. While probably having no hope of being introduced on the Late Show with David Letterman, the purpose of this program is to introduce to the reader the top 10 ideas that the author has seen in the past year that the author finds himself in the position of talking about with client's tax advisors.
As the reader will be able to ascertain, the program largely adopts the case study approach. The examples, in most cases, assume very significant estates. There is a method to that madness. Each of the ideas presented are inherently being "stress tested" by those significant estates. Stated differently, if the idea performs well in the large estate environment, chances are the idea will also perform very well for smaller estates.
The program explores not only some of the top ideas that the author has stumbled across, but also tries to focus on a wide range of family limited partnership planning topics and/or purpose-based planning strategies that the practitioner may encounter.
This program includes expert analysis by S. Stacy Eastland on audio.
Use of Materials
Audio or DVD The user should begin by watching the DVD segment or listening to the audio CD for the chapter before reading the text. The user may wish to make notes of the most important concepts and any terms that are new. Next, the user should review the learning objectives at the beginning of the chapter and read the chapter. The user should work through each of the examples. It may be helpful to highlight important material and/or to make additional notes. Next, the user should complete the study questions at the end of the chapter and review the answers. If the user answers a study question incorrectly, s/he should review the section of the text that is indicated at the end of the explanation to the study question to assure comprehension of the material. The user should review the learning objectives once more to consider achievement of the objectives. After the user has finished watching the DVD or listening to the audio CDs and reading the text and working through the study questions, s/he may wish to review her/his notes and any sections of the text or DVD or audio CDs that were difficult. When the user is ready, s/he should complete the quizzer. Reviewing notes periodically will increase retention of the material.
Online The user should begin by watching the streamed video segment, if any, or listening to the streamed audio segment, if any, for the chapter before reading the text. The user may wish to make notes of the most important concepts and any terms that are new. Next, the user should review the learning objectives at the beginning of the chapter and read the chapter. The user should work through each of the examples. After the user has studied each chapter, s/he should click on the link at the left to complete the interactive study questions. If the user answers a study question incorrectly, s/he should review the section of the text that is indicated at the end of the explanation to the study question to assure comprehension of the material. The user should review the learning objectives once more to consider achievement of the objectives. After the user has finished watching the streamed video, if any, or listening to the streamed audio, if any, and reading the text and working through the study questions, s/he may wish to review her/his notes and any sections of the text or video/audio, if any, that were difficult. When the user is ready, s/he should click on the link to the left to complete the quizzer. The user's CPE certificate will be provided immediately upon successful completion of the quizzer.
Software The user should begin by reviewing the learning objectives at the beginning of the chapter and read the chapter. The user should work through each of the examples. As the user studies each chapter, s/he should complete the interactive study questions that appear in the lower panel of the screen. If the user answers a study question incorrectly, s/he should review the section of the text that is indicated at the end of the explanation to the study question to assure comprehension of the material. The user should review the learning objectives once more to consider achievement of the objectives. After the user has finished reading the text and working through the study questions, s/he may wish to review her/his notes and any sections of the text that were difficult. When the user is ready, s/he should click on the link at the far left to complete the quizzer. The user should email her/his quizzer statistics using the quizzer submission link in the software and the user's CPE certificate will be mailed to her/him.
This program is divided into seven (7) chapters, and an index.
Chapter 1 describes the advantages of selling family limited partnership interests during the lifetime of the taxpayer for estate and gift tax planning purposes.
Chapter 2 explains the use of defined value formula clauses as the best option for valuing family limited partnership interests for estate and gift tax purposes.
Chapter 3 discusses the legal argument against the application of IRC §2036 to the family limited partnership for estate tax purposes.
Chapter 4 takes a look at a superior life-time charitable planning idea involving the use of a charitable remainder unitrust and the sale of family limited partnership interests to a grantor trust.
Chapter 5 examines the results of a superior testamentary charitable planning idea for a family limited partnership using a leveraged buyout charitable lead annuity trust.
Chapter 6 presents a family limited partnership planning idea using life insurance to hedge against a reverse freeze and cascading sales of partnership interests.
Chapter 7 identifies the ways a donor can retain control of the family limited partnership while avoiding IRC §2036(a)(2) inclusion in the estate.
Helpful Guidance
Throughout this program, the user will find explanations and discussions regarding some of the issues that often face practitioners. In order to enhance the user's comprehension of the material and highlight important practical considerations, this program includes the following designations:
A Biskpoint presents analysis or commentary that attempts to explain or clarify authoritative guidance.
A Biskalert is intended to warn the practitioner of a particular situation that may require action or other consideration by the client or the practitioner on behalf of the client.
Upon successful completion of this program, the user should be able to discuss the advantages and disadvantages of several superior family limited partnership planning ideas for estate and gift tax purposes.
Stacy Eastland is a managing director of Goldman Sachs & Co., Houston, and is widely recognized as one of the nation's leading authorities on estate planning for family businesses. He advises clients and their advisers on strategic wealth management plans, combining a variety of federal income tax, estate planning and gifting techniques. Prior to joining Goldman Sachs, Mr. Eastland was a senior partner in the law firm of Baker Botts, LLP, in Houston.
Mr. Eastland is listed in "Who's Who in America" and "The Best Lawyers in America." He has also been listed in Town & Country and in Bloomberg Personal Finance as one of the top trust and estate lawyers in the United States. Article featuring Mr. Eastland's estate planning ideas have been included in Forbes and Fortune magazines. A frequent lecturer on estate planning topics nationwide, Mr. Eastland is a Member of the International Academy of Estate and Trust Law and a Fellow of the American College of Trust and Estate Counsel (Regent for 1992/1998 term). Additionally, Mr. Eastland is also a Member of the American Bar Association (Supervisory Council Member of the Real Property, Probate and Trust Law Section from 1990-1998); a Member of the Texas Bar Association (Texas Bar Foundation Fellow); and a Member of the Houston Bar Association (Houston Bar Foundation Fellow).
He received his BS (with Honors) from Washington and Lee and his JD from The University of Texas (with Honors). (Author/Speaker)
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