Family Limited Partnerships in Estate Planning: Structuring and Income Tax Considerations, Asset Protection
Recording of a 90-minute CLE/CPE video webinar with Q&A
This CLE/CPE course will provide estate planners with a practical guide to utilizing family limited partnerships (FLPs) in estate planning under current tax law. The panel will discuss the income tax and asset protection benefits of FLPs, detail how to withstand IRS scrutiny of transfers and operations, and address the interplay between estate planners and income tax advisers, particularly concerning planning to obtain a step-up in basis upon death.
Outline
- Using FLPs for asset protection and business continuation/succession planning
- Structuring and funding options
- Section 199A deduction for FLPs
- Income tax minimization opportunities
- Using FLPs with trusts and other wealth transfer vehicles
Benefits
The panel will review these and other relevant topics:
- What are the income tax and asset protection benefits of FLPs?
- How can you withstand IRS scrutiny in operating an FLP for non-tax reasons under the business purpose rules?
- Using distributions to shift the income tax burden to limited partner family members with lower marginal income tax rates
- How does the Section 199A pass-through deduction apply to FLPs?
- Strategies for funding FLPs through nontaxable transfers and sales
Faculty
K. Eli Akhavan
Partner
Grant Herrmann Schwartz & Klinger
Mr. Akhavan focuses his practice on tax and estate planning for high-net-worth US and non-US clients. He advises... | Read More
Mr. Akhavan focuses his practice on tax and estate planning for high-net-worth US and non-US clients. He advises domestic and international individuals and families with respect to tax and estate planning for their US assets and beneficiaries. Mr. Akhavan also advises cross-border clients on all aspects of international estate matters, including foreign trusts, pre-immigration and expatriation planning, and on planning for the purchase of US residential and investment real property. He has considerable knowledge of the reporting requirements applicable with respect to foreign financial accounts and assets and with respect to FATCA and its global equivalent, the Common Reporting Standards (CRS). Mr. Akhavan's practice includes advising clients on the formation of private trust companies for purposes of wealth management and privacy.
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Cliff A. Capdevielle
Shareholder
Saltzman Mugan Dushoff
Mr. Capdevielle Capdevielle is a highly experienced probate, trust, and tax attorney with more than 30 years of... | Read More
Mr. Capdevielle Capdevielle is a highly experienced probate, trust, and tax attorney with more than 30 years of success representing trustees, beneficiaries, fiduciaries, and high-net-worth individuals in complex tax, estate, and trust, matters. Licensed in Nevada, California, and Texas, Cliff brings a unique cross-jurisdictional perspective to high-stakes disputes and sensitive family matters involving wealth transfer, inheritance, and fiduciary obligations. Before joining Saltzman Mugan Dushoff LLP, he served as Managing Attorney at Moskowitz LLP, a nationally recognized tax law firm, where he oversaw high dollar tax controversy matters. Earlier in his career, Mr. Capdevielle worked in the Tax Department at Deloitte, gaining deep experience at the intersection of tax law, finance, and business planning—expertise that now powers his sophisticated approach to estate, trust, and tax matters.
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Beth S. Cohn
Shareholder
Jaburg Wilk
Ms. Cohn chairs the firm’s Estate Planning and Business Law Department. As both a Tax Specialist certified by the... | Read More
Ms. Cohn chairs the firm’s Estate Planning and Business Law Department. As both a Tax Specialist certified by the State Bar of Arizona - Arizona Board of Legal Specialization and a Certified Public Accountant, she has a unique expertise in assisting her clients with their estate planning as well as closely held businesses. She has assisted hundreds of families - including ones with substantial assets - with their estate needs ranging from simple estate plans to complex multi-generational gifting plans. She assists families, closely held businesses owners and individuals by providing succession planning, business planning and estate planning.
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