Transfer Tax Planning

Horowitz Legal PLLC

High Net Worth Individuals

Planning to minimize Estate, Gift, and Generation Skipping Transfer taxes

We understand both the planning opportunities presented by the present contours of our transfer tax laws and the Internal Revenue Service?s enforcement practice, as well as the best techniques and strategies to shield assets therefrom, including

• Estate Freeze and Reduction Techniques: including the use of regular, serial and Walton grantor retained annuity trusts (GRATs), installment sales to intentionally defective grantor trusts (IDGTs), qualified personal residence trusts (QPRTs) and grantor retained interest trusts (GRITs)
• Valuation Discounting Techniques: including the use of family limited partnerships
• Use of Grantor Trusts to Make Phantom Gifts
• Late-in-life Planning Techniques: including self-cancelling installment notes and private annuities
• Techniques to Maximize Use of Gift Tax Exclusions: including the use of trusts with Crummey powers, Section 529 Plans and the use of the medical and education exclusions
• Life Insurance Trusts
• Special Techniques available to Foreign Persons: including the statutory exclusions for gifts of intangibles and bilateral transfer tax treaty exemptions