2025 Estate and Gift Tax Conference

Our panelists will hit the latest and greatest in charitable planning. Current numbers, hot strategies, recent cases, new laws and regulations, breaking research, and charitable giving in the headlines. The presentations will spotlight these items while also giving you practical insights on how to support your clients’ charitable giving. Will changes in tax laws motivate more charitable giving? When might a charitable gift annuity be better than a charitable remainder trust? How can you set up the purpose of a gift to make both your client and the charity happy? Our panel has the answers.

Speakers:

• David Oh
• Anna Soliman
• Bryan Douglas Kirk

The panel will discuss the numerous tax elections in estate and trust administration. You already may have heard about the marital deduction, alternate valuation, and section 6166. Those are all too common for this program. Here we will discuss some of the important—and even obscure—elections that you might not see on a regular basis. Join us on a journey through the depths of the Internal Revenue Code and the Treasury Regulations as we explore tips and traps for fiduciary income and estate tax elections.

Speakers:

• Justin Miller
• John Prokey

The panel will discuss what every practitioner should know about California’s sordid and complicated no contest history. It is necessary however to also understand the impact of the three court opinions stemming from the case of Key v. Tyler. Learn how to make a clause effective and binding.

Speakers:

• Erika J. Gasaway
• Jenni L. Harmon

This session will identify common pitfalls when dealing with art and collectibles and suggest ways to tax-efficiently own, transfer, buy, and sell valuable tangible property. We will dive into the unique issues that arise when estate planning for these special assets, including discussion of wealth transfer techniques as well as next-generation art transfer planning. We will discuss art and collectable transactions such as private sales and auction sale contracts, collection management issues, as well as estate administration pitfalls with tangible personal property. Finally, will discuss contributing artwork and collectibles to charity, negotiating gift agreements, and establishing and operating foundations and museums.

Speakers:

• Alison Sundberg Telleen
• Diana Wierbicki
• Victoria Gray

This session will take a deep dive into the common structures utilized when setting-up Single Family Offices (SFO’s) and Private Family Trust Companies (PFTC’s) used by estate planning professionals for high-net-worth clients. The most tax-efficient ways to establish and operate both distinct entities, the common (and uncommon) structures and best practices in the management and administration. How to help families achieve their objectives while also navigating the complex legal issues and maximizing estate planning opportunities. We will explore family governance and control issues and how best to align and manage PFTCs for succession planning and mitigating potential conflicts between beneficiaries and with other family members.

Speakers:

• Brendan MacMillan Chief Investment Officer (QP) Global

More and more clients are moving to out of state trusts. Hence, every practitioner should be aware of what it means for a state to be “trust friendly” Many states have modernized trust laws to promote flexibility and incorporate tax and non-tax advantages. Key attributes include the ability to establish long-term trusts for wealth enhancement, no state income tax, laws directed investments or distributions, decanting and establishing confidential trusts The panel will also discuss why situs can be important for international families.

Speakers:

• Sorya Aguirre
• James Palladino
• Lou Robinson

They say the only certainties in life are death and taxes. If that has always been true, then why do we know so little about what really happens when a partner dies? This presentation unveils the real truth about the “step-up” in basis when a partner dies and what’s left behind for the partnership and its partners. It will discuss planning opportunities before and after death, pitfalls to avoid, and unanswered questions, with a focus on “negative basis” and “negative capital” assets.

Speakers:

• Paul Lee

When interest rates are high, how are life insurance carriers, products, and programs affected? How can you guide your clients to insulate current coverage and leverage new strategies? Learn how families are structuring programs to maximize transfer tax efficiency in their planning.

Speakers:

• Lalat Pattanaik
• Kristin ‘Capritto

The United States has income tax and wealth transfer tax treaties with a number of foreign countries. Under these treaties, residents (not necessarily citizens) of foreign countries may be eligible to be taxed at a reduced rate, minimize wealth transfer taxation and avoid double taxation that can arise when two countries both have the right to tax a decedent/taxpayer. Learn about this fascinating and usually misunderstood area of wealth transfer taxation and planning.

Speakers:

• Kurt Kawafuchi
• Patrick Martin
• Luz. Villegas-Banuelos

This presentation provides a thorough overview of estate planning with IRA’s. Building from the basics of IRA’s and RMD’s, the presentation graduates to the complexities of understanding payouts to beneficiaries under the SECURE Act and SECURE 2.0 (taking into consideration July 2024’s Final Regulations and new Proposed Regulations), and ends with a dissection of testamentary trust planning with IRA’s, comparing and explaining conduit and accumulation trusts and giving some advice for deciding which to use.

Speakers:

• George Karibjanian

With just three actions and the magic of IRC section 1014’s basis step-up rule, many believe that high net-worth individuals never have to pay capital gains taxes. But the technique is in fact not as simple as it sounds. This panel will discuss how to actually implement the technique by considering economic obstacles the technique faces, how deferral strategies may or may not increase the technique’s viability, and structures to address the technique’s greatest obstacle–the estate tax.

Speakers:

• Belan Wagner
• Minna Yang

Generation-skipping transfer tax, or GST tax, can be fairly straightforward for direct transfers to individuals. However, the application of GST tax and its exemption to transfers in trust – both present and past – can surprise even the advanced practitioner. Whether you are assisting a settlor, trustee, or beneficiary, GST tax can have an impact on the advice you provide. This presentation examines some of the basic rules surrounding the application and reporting of GST tax for trusts, rules on allocations of GST exemptions, and GST tax planning strategies for various types of trusts.

Speakers:

• Simon LeBleu
• Griffin Bridges

Alternative assets comprise a significant portion of the assets of high-net-worth clients: the wealthier the client, the higher the percentage of alternative assets. A recent survey indicates that up to 50% of investments held by family offices constitute alternative assets. Real estate, private equity, commodities, and cryptocurrency are all examples of diverse types of alternative assets. This presentation will address the myriad of unique issues associated with alternative assets, including the fiduciary and planning considerations of investing in different classes of alternative assets, Environmental, Social Governance (ESG) investing, intra-family transfers, and charitable donations of such assets.

Speakers:

• Karen Sigihara
• Matthew E. Brady

Learn about significant legal and tax developments that impact contemporary wealth transfer planning. This session will analyze many of the latest regulations, rulings and cases relating to or setting new and sometimes surprising standards for current estate planning strategies, “adequate disclosure” for gift tax purposes, estate tax deductions for claims and administration expenses, valuation of closely held business equity and more.

Speakers:

• Kyle Martin
• Lauren E. Busterna
• Robin Klomparens

This panel will discuss a variety of ethical questions relating to data security and best practices using electronic media in IRS examinations and other tax matters. The speaker will cover data privacy, social media and use of email, the cloud, and other related electronic media. Also understand issues with identify theft and concerns in interacting with the IRS via online portals or other electronic means.

Speakers:

• Sharyn Fisk

In this session, we discuss available estate planning measures prior to and during a dissolution proceeding, and we guide you through the process of what to do if a spouse dies during the pendency of a divorce.

Speakers:

• Yulissa Zulaica
• Joseph Urbanski

The assets of a QTIP trust may be a substantial part of a client’s estate that are subject to estate taxes on his or her death. The provisions of the trust instrument and tax law however, complicate the use of typical estate planning strategies for QTIP trust assets. This presentation will address the special gift tax and estate tax rules that apply to QTIP trusts and discuss strategies to minimize wealth transfer taxes for QTIP trust assets in light of these special tax rules as well as typical governing instrument provisions and limitations The panelist will also address the importance of using QDOT’s when a non-citizen spouse is involved.

Speakers:

• Cynthia Brittain

In Rev. Rul. 2023-2, the IRS determined that §1014 does not apply to the assets in an IDGT upon its grantor’s death. However, not only do some commentators remain skeptical of the ruling, but in many ways the ruling does little more than to highlight the other mysteries involving grantor trust toggling, such as the basis regime that does apply on a grantor’s death and the common issue of promissory notes to or from an IDGT becoming recognized upon the grantor’s death. Indeed, many other ancillary matters remain unclear, including transactions involving a grantor trust and a third-party and the treatment of basis in a trust interest. Join this panel to benefit from the most exhaustive research into these issues yet conducted by learning the most likely answers to many of these mysteries.

Speakers:

• Mark Mullins

A Tax Court Judge, government counsel, a private practitioner, and appraisers will discuss each of their views and perspectives on valuation in the estate and gift tax arena. This session will discuss how valuation discounts are used in planning, what happens if challenged and how courts evaluate the use of valuation discounts.

The panel will also cover hot litigation topics and what everyone should learn from the most recent valuation case decisions. The panel will also provide practical solutions to managing valuation issues.

Speakers:

• Judge Halpern
• John Prokey
• Tom Berg
• Mark Higgins