Structuring Estate Freezes: Analysis with Forms

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Structuring Estate Freezes: Analysis with Forms, Second Edition is the most comprehensive, completely up-to-date authority on estate freezing. Included are all relevant IRS rulings and the text of many private letter rulings issued on Chapter 14.

This timely and practical resource contains hundreds of completed examples. Alerts and cautions highlight areas of the law and specific transactions that require special handling. More than a dozen forms facilitate estate freezing and wealth transmission techniques are included.

This treatise provides the assurance and confidence to act on every planning aspect of a client's needs with regard to Chapter 14, including:

• Personal residence trusts
• New trust evaluation rules
• Recapitalizing an established business
• Capitalizing a new business
• Lapsing rights and restrictions
• GRITS, SCINS, remainder sales, joint purchases and private annuities
• Minority discounts
• Trusts in planning for closely held businesses
• Representing spouses, siblings and multiple generations

• Structuring Estate Freezes: Analysis With Forms - Zaritsky & Aucutt
  • Part I Technical Analysis
    • Chapter 1: Background of Chapter 14
    • Chapter 2: Special Valuation Rules for Transfers of Interests in Multiclass Corporations and Partnerships (Section 2701)
    • Chapter 3: Trusts and Term Interests (Section 2702)
    • Chapter 4: Buy-Sell Agreements and Similar Arrangements (Section 2703)
    • Chapter 5: Lapsing Voting or Liquidation Rights (Section 2704)
    • Chapter 6: Special Statute of Limitations (Section 6501(c)(9))
  • Part II Estate Freezing Techniques
    • Chapter 7: Corporate and Partnership Recapitalizations
    • Chapter 8: Buy-Sell Agreements
    • Chapter 9: Outright Gifts of Interests in a Family Corporation or Partnership
    • Chapter 10: Grantor Retained Income (or Use) Trusts
    • Chapter 11: Grantor Retained Annuity Trusts and Unitrusts
    • Chapter 12: Estate Freezing and Reduction With Intrafamily Sales
    • Chapter 13: Remainder Sales and Split Purchases
    • Chapter 14: Transfers to Unrelated Persons
    • Chapter 15: Circular 230 and Sections 2701–2704 [New]
  • Appendix A. Selected Forms [Revised]
  • Appendix B. Legislative and Regulatory Materials
  • Appendix C. Full Text of Selected IRS Private Letter Rulings Issued Regarding Chapter 14