Family Limited Partnerships and Family LLCs are among the most effective planning tools for transferring family businesses from generation to generation while reducing federal estate and gift taxes. Among the many keys to successfully using FLPs is transferring control and obtaining a correspondingly steep discount on the valuation of the company. But the IRS frequently and aggressively challenges the use of FLPs and their valuations, which have made their use fraught with more risk. Led by two of the nation’s foremost experts on FLPs/FLLCs, this program will provide you with a practical guide to sophisticated planning techniques using these vehicles, structuring and drafting tips, a real world assessment of the risks involved, and recent trends in audits of FLPs.
Day 1 – October 15, 2013:
Sophisticated planning with FLP and FLLCs
Selling FLP/FLLCs – and solutions for clients who want to retain control
Use, risks and traps of defined value formula clause
Planning for challenges by IRS under Section 2036
Trends in FLP audits
Day 2 – October 16, 2013:
FLP planning to reduce GST
Post-mortem planning, including “note-freeze” partnerships
Issues on exiting/terminating FLPs
Best practices on advising clients on formation of FLP/FLLCs
S. Stacy Eastland is managing director of Goldman Sachs & Co. and widely recognized as one of the nation’s leading authorities on estate planning for family businesses. He advises clients and their advisers on strategic wealth management plans, combining a variety of federal income tax, estate planning and gifting techniques. Prior to joining Goldman Sachs, Mr. Eastland was a senior partner in the law firm of Baker Botts, LLP, in Houston. He is a member of the International Academy of Estate and Trust Law and a Fellow of the American College of Trust and Estate Counsel. He received his B.S., with honors, from Washington and Lee University and his J.D., with honors, from the University of Texas School of Law.
Stephen T. Dyer is a partner in the Houston office of Baker Botts, LLP, where his practice emphasizes the design, implementation, and defense of advanced gift and estate tax savings and business succession strategies, particularly for family-owned businesses. He also represents fiduciaries and beneficiaries in estate and trust administration. Before joining Baker & Botts, Mr. Dyer was an investment banker doing mergers and acquisitions work for Wasserstein Perella & Co., Inc., one of the nation’s leading investment banking boutiques. Mr. Dyer received his B.B.A. with honors, his MBA, and his J.D. with honors from The University of Texas.