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Estate Tax Planning with Family Entities After Powell and Strangi:20/20 Vision after Heckerling 2020 w/Sample language and clauses



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The use of traditional family limited partnerships and LLCs was significantly impacted by the Tax Court case of Powell v. Commissioner.  The Powell court, building on the Strangi decision, held that Section 2036(a)(2) applied and, therefore, all of the assets of the partnership were included in the taxpayer’s estate even though she only retained a limited partner interest.  As a result of this decision, practitioners need to modify their partnership and operating agreements for many clients.  

Fortunately for the estate planning community, this topic was discussed at length at the 2020 54th Annual Heckerling Institute on Estate Planning, and the some of the best ideas discussed and presented at this seminar will be explained and examined in this LISI Webinar.  The material in this Webinar is based on the prior LISI Webinar “Estate Tax Planning with Family Entities After Powell and Strangi” given by Alan Gassman and Ken Crotty, and has been updated as a result of  the various Powell discussions at the 2020 54th Annual Heckerling Institute on Estate Planning. 

This Webinar will include a detailed discussion of the Powell decision and how it is different from Strangi, provide practitioners with client letters and sample language that can be used in agreements, and discuss strategies that can be implemented to help fix “problems” which may exist in the current estate plan for some clients.  

In this webinar, Alan and Ken will review the following issues to help practitioners better represent their clients: 

  1. Clarify what voting rights can be retained by clients without causing Powell inclusion to apply; 

  2. Explaining what managerial roles can be kept by the client and what managerial roles should be delegated, including an analysis of how fiduciary duties impact these decisions

  3. Using special voting membership interests and special general partners to avoid the Powell issue; 

  4. Bad facts to avoid; 

  5. What you can do for clients to fix problems in existing estate plans, including satisfying the bona fide sale 

  6. Sample language and clauses to include in your agreements to provide for additional flexibility; and 

  7. Client letters.


There will be no CE for this webinar


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Alan S. Gassman, J.D., LL.M., is a partner in the law firm of Gassman, Crotty & Denicolo, P.A., and practices in Clearwater, Florida. He is a frequent contributor to LISI, and has published numerous articles and books in publications such as BNA Tax & Accounting, Estate Planning, Trusts and Estates, Interactive Legal and Haddon Hall Publishing. The Alan Gassman Channel at Interactive Legal has recently opened, and features many books and resources, including many Florida and Federal based materials, forms and resources. He is also the Moderator for Bloomberg BNA's 2017 Estate Planning Webinar Series. On February 24th Alan and his partners Christopher Denicolo and Ken Crotty will present a Bloomberg BNA Webinar at 12:30 EST on Innovative Trust Planning for Uncertain Times. You can contact Alan at agassman@gassmanpa.com for more information with respect to these programs.


Kenneth J. Crotty, J.D., LL.M., is a partner at the Clearwater, Florida law firm of Gassman, Crotty & Denicolo, P.A., where he practices in the areas of estate tax and trust planning, taxation, physician representation, and corporate and business law. Mr. Crotty has co-authored several handbooks that have been published in BNA Tax & Accounting, Estate Planning, Steve Leimberg’s Estate Planning and Asset Protection Planning Newsletters and Estate Planning magazine. Mr. Crotty is a co-author of the BNA book Estate Tax Planning in 2011 & 2012. His email address is ken@gassmanpa.com.


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