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Utilizing Freeze Partnerships to Minimize Estate Tax: Meeting Section 2701 Requirements

Note: CLE credit is not offered on this program

Recording of a 110-minute CPE webinar with Q&A

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Conducted on Wednesday, November 13, 2024

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This webinar will explain how preferred partnership freezes can minimize estate taxes for high net worth individuals and closely held businesses. Our panel of wealth transfer experts will identify ideal situations for freeze partnerships, review the mechanics of establishing these partnerships, provide comprehensive examples, and point out caveats to avoid.

Description

Preferred partnership freezes are becoming a more frequently used estate tax vehicle. These freezes allow taxpayers to transfer future appreciation of assets to younger family members, thereby avoiding estate taxation or limiting the use of the unified credit. Holding a preferred interest entitles the transferee to a preferred return on the capital contribution and in liquidation. Younger family members can purchase common interests with cash by way of gifts.

Although freeze partnerships can push down substantial appreciation of assets, properly structuring the partnership and meeting Section 2701 requirements is crucial. For example, preferred investors must receive a preferred return and the return must be payable at least annually. Not meeting Section 2701 requirements can result in a zero valuation of the preferred interest, negating the benefits of the partnership freeze. Estate planning professionals need to understand the stipulations of establishing a freeze partnership.

Listen as our panel of succession planning veterans discusses simplifying structuring and maintaining preferred partnership freezes for trust and estate advisers.

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Outline

  1. Preferred partnership freezes
  2. Estate tax benefits
  3. Ideal situations for partnership freezes
  4. Meeting Section 2701 requirements
  5. The mechanics
  6. Caveats
  7. Examples
  8. Other considerations

Benefits

The panel will cover these and other critical issues:

  1. How preferred partnership freezes mitigate estate tax
  2. Identifying ideal assets and estates for freeze partnerships
  3. Meeting IRC Section 2701 requirements
  4. Caveats to avoid when structuring and maintaining freeze partnerships

Faculty

Lipoff, Lawrence
Lawrence M. Lipoff, CPA, TEP

Director
CohnReznick

With more than 30 years of experience, Mr. Lipoff specializes in the delivery of domestic and international private...  |  Read More

Radford, Matthew
Matthew J. Radford, CPA

Founder
Radford Advisory

Mr. Radford has focused his practice on the development and implementation of business succession and wealth...  |  Read More

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