Tax and Business Planning

• Collaborated on the design of many GST exempt trusts, including creating many tailored economic and tax models for installment sales to grantor trusts and sales in exchange for self-cancelling installment notes.
• Assisted in the design and implementation of many trust decanting transactions to accomplish client goals such as to add flexibility to existing but outdated trust structures and minimize state-level tax burdens.
• Designed many annual gift trusts and education trusts for grandchildren as an alternative to less flexible saving-type accounts for minors.
• Designed many irrevocable life insurance trusts and funding transactions, including structuring many life insurance sales that maintain favorable tax treatment for policy proceeds.
• Prepared and reviewed many U.S. federal and state gift and estate tax returns and represented taxpayers in IRS gift and estate audits.
• Prepared comprehensive estate plans for high-net worth, business-connected clients and their family members, including the CEO of a publicly-traded company, many closely-held business owners, and philanthropists.
• Designed and implemented strategies to assist clients with existing trust structures, including renegotiating sale strategies and cash flow management.

International Private Client Planning

• Prepared comprehensive estate plans for individuals and couples that have citizenship or residency in multiple jurisdictions and/or assets in multiple jurisdictions.
• Represented the executors of many foreign estates with dual-citizen/resident decedents or global assets, including preparation of non-U.S. citizen/resident estate tax returns, which often include various favorable treaty-based return positions (including recently United Kingdom, Japan, France, Switzerland, Channel Islands, Canada, and Spain).
• Designed numerous structures for high net worth foreign individuals and family groups to hold U.S. situs assets.
• Designed many structures for foreign individuals and family groups to hold personal-use and rental real estate in the U.S.
• On multiple occasions advised the trustees of U.S. trusts regarding the owners of non-U.S. assets and the implications and considerations for making distributions to beneficiaries who previously expatriated from the U.S.
• Assisted many non-U.S. clients with IRS controversies, including gift tax examinations, reasonable cause and voluntary disclosures.
• Opined on the U.S. tax classification of many offshore entities, pensions and other arrangements, such as Liechtenstein anstalts and stiftungs, German usufructs, holding companies and land trusts, and Australian superannuation funds and unit trusts.
• Assisted numerous clients with foreign informational return matters, including foreign bank account reports (FBAR), foreign financial assets, foreign mutual funds and receipt of foreign gifts and inheritances.
• Analyzed and managed complexities of U.S. and foreign trusts and estates, including implications to beneficiaries on distribution and inheritance.

Charitable Planning

• Designed multiple charitable lead trusts and charitable remainder trusts.
• Assisted in the establishment of a community-owned national public radio member station and in obtaining tax-exempt status, being the first transaction of its kind in the U.S.