Family Limited Partnership Update, Part 1
The shifting regulatory and financial climate is changing the nature of the threats to and opportunities for using Family Limited Partnerships in estate planning. The Obama Administration has proposed substantial revisions to Section 2704 which would substantially reduce the tax benefits of FLPs and the IRS continues its aggressive audit program. More deeply, the opportunities for using FLPs are changing, too, with dramatically lower interest rates and certain arbitrage techniques now available. Led by the nation’s foremost practitioners in this area – Stacy Eastland and John Porter - this biennial update will provide you a comprehensive case law, regulatory and legislative update and a practical guide to the new opportunities and techniques for using FLPs in your estate planning practice
Day 1 – November 10, 2009:
- Case law, regulatory and proposed legislation update
- Discussion of Jorgensen and Miller
- Obama Administration proposed changes to Section 2704
- Issues on exiting/terminating FLPs
S. Stacy Eastland
is a managing director of the Goldman Sachs & Co. and is 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. Mr. Eastland is listed in “Who's Who in America” and “The Best Lawyers in America.” He has also been listed in Town & Country and in Bloomberg Personal Finance as one of the top trust and estate lawyers in the U.S. Articles about Mr. Eastland’s estate planning ideas have been featured in Forbes and Fortune magazines. A frequent lecturer on estate planning topics nationwide, Mr. Eastland 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 and his J.D. from The University of Texas School of Law, with honors.
John W. Porter is a partner in the Houston office of Baker & Botts, LLP, where his practice focuses on gift, estate and income tax disputes, valuation of business interests and fiduciary issues. He is nationally recognized for his expertise in representing taxpayers before and against the IRS in estate and gift tax controversies, particularly those involving hard-to-value assets such as interests in FLPs and LLCs. He frequently advises and represents fiduciaries and beneficiaries of trusts and estates with respect to administration and fiduciary duty issues. Mr. Porter is a Regent and Fellow of the American College of Trust and Estate Counsel. He is a graduate of Texas A&M University, where he received his B.B.A., and Baylor University School of Law, where he received his J.D. Mr. Porter is also a Certified Public Accountant.
