Wealth Transfer

  • We represented a married couple whose $13 million estate included an operating corporation and numerous limited liability companies, one of which owned substantial commercial real estate.  Most of the real estate was used in the business operations, but some was not.  Two of the couples’ three children were involved in the business and one was not.  Following the death of husband, through a combination of strategic asset allocation among sub-trusts, disclaimers, gifts, and intra-family sales, we helped the extended family reorganize the business and real estate property ownership.  As a result, all of the business-related real estate and all of the stock of the operating company are now owned by the children and grandchildren who are involved in the business.  Other property formerly held in entities is now owned by those not involved in the business.  In the process, the widow fully utilized her roughly $5 million gift tax exemption, and property tax reappraisal was minimized.
  • A recent federal tax law change allowed just a two-week generation-skipping transfer tax "holiday" for transfers to certain kinds of trusts for benefit of grandchildren.  Within that two-week window, we helped the client refinance an $8.5 million promissory note owed to her by a grandchildren's trust she had previously created.  She then forgave the note.  As one of the benefits of this planning, she saved over $2,500,000 in generation-skipping transfer tax.
  • An irrevocable trust established 30 years ago provided for asset distributions under standards and at beneficiary ages that no longer made sense in light of changing circumstances.  We asked the court to modify the trust in accordance with certain Probate Code authority.  We received a court order that modified the trust and will allow the trustee to properly administer the trust for several more decades.

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