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Tax and Estate Planning

Tax issues affect virtually every individual and corporate client of MPS. Beyond offering general tax planning for individuals and businesses, our tax attorneys routinely collaborate on matters ranging from employment law and employee benefits to mergers and acquisitions and real estate transactions. We work with our business owner clients to assimilate their estate planning and business succession planning with their long-range objectives.

For individuals and families

  • Wills and trusts
    •  
      • Revocable living trusts
      • Life insurance trusts
      • Gift trusts for children and grandchildren
      • Generation skipping dynasty trusts
      • Charitable remainder trusts
      • Grantor retained annuity and income trusts
      • Qualified personal residence trusts
      • Intentionally defective grantor trusts
  • Probate and estate administration
  • Retirement planning
  • Asset protection planning

For business and corporate entities

  • Business succession planning
  • Family limited partnerships and LLCs
  • Qualified and nonqualified retirement plans
  • Executive compensation and fringe benefit programs
  • Tax planning for mergers and acquisitions and real estate transactions

Representative Transactions

  • Gift transfer of real estate with good cash flow and appreciation potential to an intentionally defective grantor trust (IDGT) for the benefit of grantors adult children, using LLC interests with valuation discounts. The grantor is responsible for income taxes on trust income because of the IDGT without additional gift tax consequences.
  • Transfer of LLC holding marketable securities to a rolling grantor retained annuity trust (GRAT) with favorable market conditions and interest rates, using zeroed out GRATs with 2-year terms. The remainder interests were transferred to an IDGT for the benefit of the grantors children.
  • Advised client with respect to transfer of secondary residence to a qualified personal residence trust when interest rates were favorable to artificially limit the value of the remainder interest that will pass to the grantors children at the end of the trust term.
  • In anticipation of a future sale of company, the transfer of a significant minority interest to a short-term zeroed out GRAT using valuation discounts, when interest rates were favorably low. Intent was to trap sales price premium in the remainder interest of the GRAT which will go to an IDGT for the grantors children and grandchildren.
  • Transfer of marketable securities to family LLC and subsequent transfers, using valuation discounts to children and trusts for grandchildren, utilizing annual exclusion gifts, gifts allocated to the lifetime exempt amount and the generation-skipping exemption.
  • Use of the 2012 lifetime gift tax exemption by transferring liquid investments to IDGTs for the children, with broad trustee discretion for distributions during the lives of the grantors, to optimize benefit of having the grantors pay for taxes of the IGDTs.
  • Sale of a minority interest in a rapidly growing closely held company using a minority discount to an IDGT that also owns life insurance on the grantor.
  • Analysis of all 2012 estate, gift and income tax consequences of $20 million of aggregate family gifts and $5 million of aggregate charitable gifts, including coordination with investment advisors to transfer low basis assets for charitable purposes and advising sale of assets in order to gift cash in the taxable transfers so that capital gains were paid by the donor, further reducing the taxable estate, and minimizing future capital gains to be paid by donees in due course at 2013 and later rates.
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