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PROGRAM CONTENT

For each of the strategies, presenters will provide a general overview, income and transfer tax implications, wealth transfer implications, investment opportunities, insurance opportunities, legal implications, general planning and design ideas, suitable assets, qualified prospects, cash flow issues, client benefits, and risks. Participants will receive a course notebook and a CD containing the presentation materials for the following strategies*:

  1. Testamentary Charitable Lead Annuity Trust TCLAT Eliminate estate taxes and transfer the entire value of the estate to heirs within 15 years of death. Works best with FLP and good life insurance planning.
  2. Accelerated Inheritance Trust Nongrantor Lifetime CLAT Transfer substantial wealth to heirs estate and gift tax free without the delays of a TCLAT. Works best with FLP and good life insurance planning.
  3. Super CLAT Grantor Lifetime CLAT Get an income tax deduction for passing substantial assets to heirs estate and gift tax free. Works best with FLP and good life insurance planning.
  4. Simulated Lead Trust SimCLAT A very powerful alternative to the Super CLAT that achieves similar objectives while eliminating phantom income problems.
  5. Deferred Gift Annuity and Simulated Deferred Gift Annuity DGA A powerful and sometimes superior alternative to a CRT.
  6. Employee Stock Ownership Plan ESOP Business owners can convert equity into cash tax-deferred while retaining control of the company.
  7. Charitable Employee Stock Ownership Program ChESOP The client benefits both himself and charity by adding an income tax deduction and increased investment flexibility to an ESOP.
  8. FLIP CRT Sell a business, stocks, or investment property tax deferred and then provide a virtually guaranteed stream of retirement income.
  9. Private Annuity Trust A noncharitable alternative to a CRT that allows for tax-deferred asset sales.
  10. Sale to Defective Trust IDIT Transfer assets to heirs at a discount and freeze the estate tax value.
  11. Qualified Personal Residence Trust QPRT Transfer up to three homes to heirs estate and gift tax free.
  12. Amendable Irrevocable Super Trust - A life insurance trust with provisions giving the grantor rights to change the terms and access the cash value.
  13. Split Dollar Solutions Tax-efficient methods of paying for large life insurance premiums.
  14. Family Foundations A very popular tool even for moderately wealthy clients that is often used in combination with other advanced tools. We will discuss the three primary types of family foundations (donor advised funds, private foundations, and supporting organizations) and their relative advantages and disadvantages.

*Course content subject to change based on tax and other matters

Disclaimer: Split dollar arrangements are subject to IRS Notice 2002-8 and Proposed Regulations that apply for purposes of federal income, employment and gift taxes. The Sarbanes-Oxley Act of 2002 makes it unlawful for a company regulated by the Securities Exchange Act of 1934 ("34 Act") to directly or indirectly make loans to its directors or executive officers. This includes not only companies required to register their securities under the 34 Act, but also companies required to file reports (i.e. 10k and 10Qs) under the 34 Act. Please consult with your attorney before purchasing a life insurance policy that will be corporate/business owned or used in a split dollar arrangement to determine what restrictions may apply. This information is not intended to be tax advice. Please consult your tax advisor for more information regarding the tax implications of this policy.

U.S. Treasury Circular 230 requires that this firm advise you that any tax advice provided was not intended or written to be used, and cannot be used by you, for the purpose of avoiding penalties that the IRS could impose upon you.