Assignment
You are an associate in a boutique tax consulting firm that specializes in the real estate industry. You have been assigned to work with a client who needs advice on the tax implications of his business holdings, which include Skyscrapers, a commercial real estate firm organized as a sole proprietorship with a fair market value of $1 billion. He is considering transferring partial ownership of the Skyscrapers to both of his children and selling a 10% interest to an unrelated third party.
Your manager has asked that you prepare a memorandum informing management of the estate and gift tax consequences of these potential transactions in addition to a cost-benefit analysis. Be sure to cite appropriate case law, statutes, and regulations in your memorandum.
You will submit a memo describing how you will incorporate trusts into the estate plan you started in Milestone One. Include a quantitative model (in Excel) explaining how the use of the trusts and the family limited partnership can reduce the family's estate tax over time. Show how the transfer of ownership in the present via gifts or the formation of trusts will ensure a greater appreciation in value of the younger generation's ownership interests in the family enterprise over time. Conclude whether or not the strategy is worthwhile and is ethically sound. Cite appropriate statutory authority, case law, and/or AICPA Code of Conduct or ABA Model Rules of Professional Conduct to support your conclusions.
Specifically, the following critical elements must be addressed:
I. Utilize intentionally defective grantor trusts to accomplish long-term minimization of the client's tax liability. Consider the mechanics of these estate planning vehicles and the appropriate authority to cite.
II. Tables and Calculations: Excel Documentation
A. Consider how the strategy maximizes the amount of transferred wealth to the client's children over time and explain the amount in an Excel spreadsheet.
B. Given the income tax consequences, conclude whether or not the strategy is worthwhile and is ethically sound. Consider justifying the strategy in comparison to an alternative transaction.
Attachment:- Assignment.rar