Trusts and Estates, Private Client & Tax Exempt Organizations
The firm's practice in Trusts & Estates, Private Client and Tax-Exempt Organizations encompasses all aspects of estate planning and administration, including international estate and tax planning for U.S. citizens and nonresident aliens with global interests, family business succession planning and Patriot Act compliance for tax-exempt organizations.
- Wealth planning, and estate, gift and income tax planning for high net worth individuals, entrepreneurs and senior executives, including sophisticated tax minimization strategies, designing and implementing domestic and international tax and asset protection strategies, tax pre-planning for IPOs, private equity transactions and other liquidating events.
- Dynastic heritage planning, pre-immigration and expatriation tax planning, designing and implementing domestic and offshore private placement variable life insurance programs, establishment and governance of tax-exempt organizations including compliance with the Patriot Act.
- Planning and implementation of simple and complex wills, trusts, powers of attorney, living wills and health care proxies, deferred compensation packages for senior executives, pre-and post-nuptial agreements, and formation of family trusts, family partnerships and other vehicles to protect, preserve and increase family wealth for future generations.
- Succession planning for privately-held companies and partnerships including the implementation of buy/sell agreements and concordant insurance strategies.
- Administration of large and complex estates and trusts concerning all types of assets including commercial real estate and closely-held business interests.
- Preparation and filing of gift tax returns, estate tax returns, fiduciary income tax returns and fiduciary accountings.
- Representation and audit defense before the Internal Revenue Service.
- Representation with respect to all matters coming before the Surrogates' Court.
- Elder care planning, including advice on rights under Medicaid.
- Trust and estate litigation including contested probate proceedings.
- Structuring of derivative insurance products, business trusts and entity design for investment purposes.
- Case management of multinational settlement involving the creation of numerous domestic and foreign security interests to securitize periodic payments totaling 9-figures.
- Brought to a successful conclusion a complex 8-figure estate, averting potential litigation by negotiating and implementing the dismantling of a real estate investment partnership.
- Brought to a successful conclusion an 8-figure estate, defending the estate in a tax audit that resulted in no additional tax due the IRS.
- Prepared successful IRS Private Letter Ruling application for "sailing permit" so that high net worth individual could repatriate back to home country without adverse tax consequences.
- Provided tax, pension and structuring advice to a large, public, tax-exempt organization in connection with forming an independent not-for-profit spin-off corporation.
- Created a variety of structures for participation in option agreements, installment sales agreements and stock purchase agreements.
- Advised investment bank on the structuring of investments in derivative insurance products including life settlements and premium financing.
- High net worth individuals
- Senior executives
- Hedge fund and investment company principals
- Multinational corporations
- Family businesses
- Principals of closely held manufacturing, technology, real estate and service companies
- Principals of development stage and emerging companies
- Entertainers, sports figures and other high profile individuals
- Family offices
- Physicians, medical groups and other joint ventures
- Charitable organizations
- Financial service companies, banks and trust companies
- Investment banks trading in insurance derivatives