Acknowledgments
About the Author
Introduction
Chapter 1 Introduction
Chapter 2 Inventory of the Client’s Assets and Objectives
Scope of Factual Analysis
Family
Assets and Liabilities
Cash Flow Analysis
Present Objectives for Estate Disposition
Chapter 3 Preliminary Estate Planning Considerations
Expanded Responsibilities of the Professional Tax Advisor
Facilitating Lifetime Capital Formation
Fundamental Federal Income Tax Planning
Managing and Structuring the Closely Held Business Ownership: Family Business Succession Planning
Additional Important Preliminary Planning Inquiries
Chapter 4 The Basic Federal Transfer Tax and Income Tax Structure
Estate, Gift and Generation-Skipping Transfer Taxes
Related Federal Income Tax Considerations
Chapter 5 Fundamental Testamentary Planning
Basic Mechanisms for Transferring Property
Trusts
Credit Shelter Trust
Estate Tax Marital Deduction Transfers
Powers of Appointment
Chapter 6 Lifetime Asset Transfers
Lifetime Gifts—Arguments For and Against
Basic Federal Tax Considerations
Methods of Completing Gifts
Specific Types of Gifts
Chapter 7 Intrafamily Transfer Alternatives to Gifts
Intrafamily Sale/Leaseback or Gift/Leaseback
Intrafamily Installment Sales
Interest-Free Loans of Money
Loans of Property or Credit
Tax-Free Property Exchanges with Family Members
Private Annuities
Joint or Split Purchases
Sale of Remainder Interest in Property
Grantor Retained Annuity Trust and Unitrust
Personal Residence Trusts
Transfers of Family Properties Summarized
Chapter 8 Generation-Skipping Transfers
Purpose of the Generation-Skipping Transfer Tax
Definitional Provisions
Tax Computation
Exemptions
GST Tax Planning Considerations
Chapter 9 Special Nonprobate Planning Situations
Joint Property
Community Property
Life Insurance
Commercial Annuities
Charitable Transfers
Foreign Trusts
Chapter 10 Special Business Planning Situations
Family Business Planning Options
Closely Held Family Corporations
Closely Held Partnerships and Limited Liability Companies
Special Valuation for Family Farms and Real Property
Qualified Family-Owned Business Interests
Chapter 11 Special Executive Compensation/Deferred Benefits Estate Planning
Executive Compensation Planning
Qualified Pension and Profit-Sharing Plans
Self-Employed Individual
Individual Retirement Account
Business-Originated Life Insurance
Chapter 12 Post-Mortem Estate Planning
Planning Options
Income Tax Planning Opportunities
Renunciations and Disclaimers
Waiver of Fee by Fiduciary
Solving Estate Liquidity Problems
Alternate Valuation
Chapter 13 Estate Planner-Client Relationship
Professional’s Responsibility
Determining the Amount of the Estate Planner’s Fee
Income Tax Deduction of Estate Planning Fees
Appendix
Bibliography