Thursday, November 21, 2019, 1:00-2:00pm
"Asset freezes" transfer future appreciation in a closely-held company or other asset from a senior generation to a junior generation, reducing the tax exposure of the senior generation and providing that any appreciation will be taxable at the generally lower rates of beneficiaries.
Asset freezes use a variety of trusts and techniques to achieve this shift in taxable appreciation. Because freezes are subject to abuse, they are frequently challenged by the IRS.
If carefully planned, drafted, and administered, however, asset freeze platforms are effective tools for tax reduction while the senior generation still retains income from the asset.
This program provides a practical guide to the techniques, risks and opportunities of asset freezes.
- Use of retained interest trusts to shift asset appreciation – GRATs, GRITs, GRUTs
- Installment note sales of closely-held companies to heirs
- Use of self-cancelling installment notes and private annuities
- Qualified Personal Residence Trusts
- Income tax consequences of asset freezes
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