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Training Course Syllabus:

This seminar is designed for accountants, succession and tax attorneys, and financial and estate planners. Learn how to identify and suggest creative solutions to your client’s problems, and more importantly how to avoid costly errors and omissions. The basics will be covered in detail along with selected sophisticated topics, including:

• Advanced Planning With The Irrevocable Life Insurance Trust

• The Zeroed-Out GRAT

• The Sale To A Grantor Trust And Variations

• Advanced Planning With Charitable Remainder Trusts

• Advanced Planning For The Elderly

• Preferred Limited Partnerships

• Planning For Non-Citizen Spouses

• Advanced Planning For Dynasty Trusts

8:30 a.m. - 9:20 a.m.

I. Advanced Planning With The

Irrevocable Life Insurance Trust

A. Single Life vs. Second To Die Insurance

B. Flexibility In Drafting The Trust

C. Use Of Trust Protector Or Independent Party

D. Avoiding The Three Year Rule

E. Family Partnerships As An Alternative

F. The Marital Deduction Failsafe

G. The Spouse As Trustee

H. The Wrap Trust

I. Considerations With Crummy Powers

J. GST Issues And The New Rules On Allocation Of Exemption

9:20 a.m. - 10:00 a.m.

II. The Zeroed-Out GRAT

A. Analysis Of The Walton Case

B. IRS Position

C. Use Of The 120% Rule On GRAT Payments

D. Contingent Spousel In Trusts

E. Drafting The GRAT

F. Result On Death Of The Grantor At Any Time

G. Analysis Of The Benefits And Risks

H. Profile Of Appropriate Client

10:00 a.m. - 10:10 a.m.


10:10 a.m. - 11:15 a.m.

III. The Sale To A Grantor Trust And


A. Explanation Of The Income And Transfer Tax Benefits

B. “Seed Money” And Loan Guarantees

C. Generation Skipping Tax Issues

D. The Zero Tax Buyout

E. Use With SCINs And Private Annuities

F. Continuation Of The Trust As A Grantor Trust After The Note Term

G. Tax Reimbursement Clauses

H. Grantor Powers

11:15 a.m. - 12:00 p.m.

IV. Advanced Planning With Charitable

Remainder Trusts

A. Examples Of Calculations

B. Inter Vivos vs. Testamentary

C. Use Of The 50%/10% Rules

D. Short Term CRTs

E. Use In Sec. 1374 Situations

F. UBIT And Private Foundation Issues


H. Wealth Replacement

12:00 p.m. - 1:00 p.m.

Lunch (On Your Own)

1:00 p.m. - 1:45 p.m.

V. Advanced Planning For The Elderly

A. Super Crummy Trusts

B. 3 Year Reversionary And 3 Year Income Retention Trusts

C. Advisability Of Paying Gift Tax

D. Cheap Step Ups In Basis

E. FLPs And The Hackl Case

F. QPRTs For The Very Elderly

1:45 p.m. - 2:30 p.m.

VI. Preferred Limited Partnerships

A. The 10% Rule

B. Compared To Other Freeze Transactions

C. Structuring And Drafting

2:30 p.m. - 2:40 p.m.


2:40 p.m. - 3:20 p.m.

VII. Planning For Non-Citizen Spouses

A. Reduced Lifetime Marital Deduction

B. Qualified Domestic Trusts Rules And Drafting

C. Alternative Structures In “Napoleanic” Jurisdictions

D. Foreign Trust Issues

3:20 p.m. - 4:30 p.m.

VIII. Advanced Planning For Dynasty


A. Pitfalls Of The ETIP

B. Reverse QTIP Elections

C. The Power And Pitfalls Of Dynasty Trusts

D. Sales Of Remainder Interests To Avoid The ETIP Issues

E. Drafting Issues

Seminar Summary:

 (see full course description)

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