Giving Strategies Leveraging Available Credits and Exemptions From Federal Taxes
Prepares sophisticated giving strategies designed to leverage clients’ available credits and exemptions from federal estate, gift and generation-skipping transfer taxes, including grantor retained annuity trusts, qualified personal residence trusts, charitable lead trusts, charitable remainder trusts and sales to intentionally defective grantor trusts.
Trust Modification, Termination and Decanting of Trusts
Represents clients in connection with the trust modification, termination and decanting of trusts.
IRS Audits of Gift Tax Returns
Represents clients in audits of gift tax returns by the Internal Revenue Service.
Application of U.S. Income and Wealth Transfer Taxes
Advises international clients with U.S. ties and U.S. citizens living abroad on the application of U.S. income and wealth transfer taxes to them, including representing clients before the Internal Revenue Service in connection with previously unreported offshore income and assets.
Private Foundations and Restrictive Stock
Formed private foundations to be funded with restrictive stock.
National Donor Fund Operation and Administration
Advised a national donor fund on all aspects of its operation and administration, including corporate governance and management, call center operation, gift processing and donation management, planned giving, customized grant making, marketing, and private label products.
Private Foundations and Investment Partnerships
Represents private foundations in connection with investments in partnership interests and other assets generating unrelated business taxable income.