Estate Tax Planning

• Review of estate and gift planning
• Advice re: financial and health power of attorney
• Trusts
  • foreign trusts
  • revocable and irrevocable trusts
  • qualified domestic trusts
  • charitable and estate planning trusts
• Introductions to local and international legal counsel
• Establish Charitable Foundations - foreign and U.S.
• Valuations for gift and estate purposes
• Formation of family limited partnerships for estate planning
• Foreign Trusts for wealth preservation and international investment
• Selection of investment advisors and fiduciaries (U.S. and foreign)
• Analyze taxation of plan distributions (qualified and nonqualified plans)
• Preparation of gift and estate tax returns

Complex Estate Planning for Family Holdings

The client was a well-known family in San Francisco with multiple property and business holdings. We were requested to formulate a comprehensive estate plan. The plan included the formation of a family limited partnership to take advantage of lifetime transfers of assets at deep discounts, and advice on how to establish a private foundation to retain control over significant assets for future generations.

International Estate Planning for Hong Kong Family

Our client's family, resident in Hong Kong, owns significant commercial real estate in the Bay Area. The family was interested in restructuring their ownership in the various U.S. real estate partnership holdings without incurring gift taxes. By using foreign limited liability partnerships and U.S. corporations, the family was able to shift a major part of the estate to the next generation in the U.S.

Foreign Foundation for Maximum Tax Benefits and Flexibility

We were retained by an executive of a technology company to undertake international estate planning. We advised about the benefits of using a foreign charitable foundation over a domestic foundation for assets expected to increase substantially over the next several years. As a result, we provided our client with an extensive memorandum concerning the use of a foreign charitable foundation, and how assets in the US could be invested in a flexible manner without violating normal self-dealing rules or prudent investor without violating U.S. tax-exempt statues.

Use of Corporate Reorganizations and Limited Liability Companies to Implement Estate Planning

We were engaged to formulate a strategy whereby new acquisitions would be owned principally by the next generation even though the equity used to acquire new businesses the ventures belonged to the parents. The reorganization provisions of the Internal Revenue Code allowed several business holdings, which were held in one company to be split up into several separate companies. With the use of limited liability companies to acquire new interests and to transfer existing interests at discounted values, the parents retained control of the assets while shifting beneficial ownership to the children.

Foundation Planning Preserves Estate for Generations

Our clients recently disposed of their interest in a company in a tax-free exchange of stock (referred to as a "B" reorganization) with a publicly traded company. We then assisted with tax strategies to minimize the income tax on future investments and helped to establish several family trusts and two foundations. Our work currently involves ongoing tax and accounting work for family members, several trusts, and the foundations.