Wills, Trusts & Estates Prof Blog

Editor: Gerry W. Beyer
Texas Tech Univ. School of Law

Friday, November 15, 2013

CLE on Chapter 14 Essentials: A Practitioner's Guide Though the Minefield

Bloomberg BNA  is sponsoring a CLE entitled, Chapter 14 Essentials: A Practitioner's Guide Though the Minefield, on Tuesday, November 19, 2013 at 12:30 -2:00 Eastern Time.  Provided below is a description of the event:

The provisions under Chapter 14 of the Internal Revenue Code have existed for over twenty years yet many of the draconian gift and estate tax provisions are not well understood by Trusts and Estates professionals.

This live webinar will provide a discussion of the many estate and gift tax pitfalls that practitioners need to keep in mind under these provisions whenever structuring transactions between family members. It will also include a broad overview of the statutory provisions of 2701 through 2704 and will also include discussions of the policy reasons behind the sometimes confounding rules included in Chapter 14.

Practical applications and the many pitfalls that practitioners need to keep in mind in connection with popular wealth planning techniques will be analyzed, including as well as:

  • GRATs, QPRTs and Sales of Remainder Interests
  • Section 2701 compliant Preferred Partnerships
  • "Vertical Slice" fund carried interest transfer planning and "Non-Vertical" alternatives
  • Sales to Intentionally Defective Grantor Trusts
  • Buy-Sell Agreements and Section 2703 challenges
  • FLP challenges under 2703 and other sections
  • Marital Deduction mis-match problems that can arise as a consequence of Section 2703 (as well as Section 2036)
  • Valuation provisions under Section 2704.

Educational Objectives

  • Obtain a "Big Picture" understanding of Pre-Chapter 14 law and what Chapter 14 was broadly intended to accomplish.
  • Understand the provisions of Sections 2701, 2703, 2703 and 2704 of the Code and their relative tax consequences.
  • Understand the policy reasons behind these provisions.
  • Understand where exceptions to these Code Sections exist and planning opportunities.
  • Highlight areas where the Chapter 14 "Red Flags" exist in connection with popular estate planning techniques.

Who Should Attend?
Trusts and Estates practitioners including lawyers, accountants, private bankers and financial planners.

Prerequisite: None
Level: Intermediate
Delivery method: Group live
Recommended CPE credit: 1.5 credits


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