Program Details
2025-08-21 12:00:00
Over 1,000+ webinars
Course Overview
2025-08-21 12:00:00
4h CLE Credits
Intermediate
4
12:00 pm - 12:30 pm ESTThis session traces the evolution of LLCs following the check-the-box regulations and explains how partnership taxation offers advantages like flexible entry/exit, debt basis allocation, and special allocations. Attendees will learn entity classification options and compare LLCs to family limited partnerships for estate planning purposes.
Jay D. Adkinson
Robert S. Barnett
Jeff Cunningham
Rustin Diehl
Allen N. Bradley 12:30 pm - 1:00 pm ESTExplore critical misalignments between operating agreements and estate planning structures, including permitted transferee provisions and gift qualification requirements. This session covers valuation discount strategies, Section 2036 traps, and communication protocols between legal and CPA teams.
Jay D. AdkinsonRobert S. BarnettJeff CunninghamRustin DiehlAllen N. Bradley 1:10 pm - 1:40 pm ESTMaster the complexities of Section 704(b) allocation requirements, capital account maintenance, and substantial economic effect safe harbors. This session also addresses structuring manager versus member control provisions and drafting effective buy-sell clauses with proper valuation mechanics.
Jay D. AdkinsonRobert S. BarnettJeff CunninghamRustin DiehlAllen N. Bradley 1:40 pm - 2:10 pm ESTLearn how profits interests can shift future appreciation to younger generations while freezing the grantor’s estate value through a detailed case study of a food manufacturing business succession. This session examines F reorganizations, freeze structure tools like GRATs and IDGTs, and coordinated wealth preservation planning.
Jay D. AdkinsonRobert S. BarnettJeff CunninghamRustin DiehlAllen N. Bradley 2:20 pm - 2:50 pm ESTNavigate the BBA centralized partnership audit regime, including election-out requirements, audit stages, and the partnership representative’s expanded authority. Attendees will learn critical operating agreement drafting considerations and lessons from conservation easement syndication disputes.
Jay D. AdkinsonRobert S. BarnettJeff CunninghamRustin DiehlAllen N. Bradley 2:50 pm - 3:50 pm ESTUnderstand how charging orders function as judicial remedies and the numerous exceptions that allow creditors to circumvent charging order exclusivity, from single-member LLCs to bankruptcy proceedings. This session provides planning strategies including hot/cold trust structures and protected series LLCs for optimal asset protection.
Jay D. AdkinsonRobert S. BarnettJeff CunninghamRustin DiehlAllen N. Bradley 4:00 pm - 4:30 pm ESTAddress the unique challenges of holding digital assets in LLCs, including IRS classification as property, basis tracking difficulties, and the upcoming Form 1099-DA requirements. Learn essential operating agreement provisions for key management, custody protocols, and estate planning considerations for the digital asset multiverse.
Jay D. AdkinsonRobert S. BarnettJeff CunninghamRustin DiehlAllen N. BradleyJay D. Adkisson is uniquely qualified in creditor structuring and asset protection through LLCs, combining hands-on litigation experience with expertise in shaping national legislation and publishing authoritative works on charging orders and debtor-creditor law.
Robert S. Barnett, JD, Masters (Taxation), CPA, is a founding partner of Capell Barnett Matalon & Schoenfeld LLP, Attorneys at Law. His practice is highly concentrated in the areas of taxation, trusts, estates, corporate and partnership law, and charitable planning. He brings creative and practical solutions to estate and business planning, drawing on extensive experience that includes Surrogate’s Court practice, tax dispute resolution, Tax Court representation, and the structuring of financial transactions and charitable gifts. A prolific lecturer and published author on tax and business law, Mr. Barnett is an active participant on numerous professional and charitable boards.
Jeff Cunningham possesses transactional depth and drafting acumen focused on LLC operating agreements, including ownership structuring, buy-sell planning, and control provisions that balance tax efficiency, legal protection, and real-world functionality.
Rustin Diehl works at the intersection of innovation and tax-savvy estate planning, specializing in freezing structures and digital asset protection through LLCs, translating complex IRS rules into practical planning tools.
Allen Bradley is a trusted advisor in corporate and partnership taxation with strengths in transaction structuring, executive compensation, and compliance planning, frequently involving high-level tax analysis and negotiation with federal authorities.
Jay D. Adkisson is uniquely qualified in creditor structuring and asset protection through LLCs, combining hands-on litigation experience with expertise in shaping national legislation and publishing authoritative works on charging orders and debtor-creditor law.
Robert S. Barnett, JD, Masters (Taxation), CPA, is a founding partner of Capell Barnett Matalon & Schoenfeld LLP, Attorneys at Law. His practice is highly concentrated in the areas of taxation, trusts, estates, corporate and partnership law, and charitable planning. He brings creative and practical solutions to estate and business planning, drawing on extensive experience that includes Surrogate’s Court practice, tax dispute resolution, Tax Court representation, and the structuring of financial transactions and charitable gifts. A prolific lecturer and published author on tax and business law, Mr. Barnett is an active participant on numerous professional and charitable boards.
Jeff Cunningham possesses transactional depth and drafting acumen focused on LLC operating agreements, including ownership structuring, buy-sell planning, and control provisions that balance tax efficiency, legal protection, and real-world functionality.
Rustin Diehl works at the intersection of innovation and tax-savvy estate planning, specializing in freezing structures and digital asset protection through LLCs, translating complex IRS rules into practical planning tools.
Allen Bradley is a trusted advisor in corporate and partnership taxation with strengths in transaction structuring, executive compensation, and compliance planning, frequently involving high-level tax analysis and negotiation with federal authorities.
Requirements
The Alabama State Bar MCLE Commission requires attorneys to complete 12 credits, including 1 ethics, by December 31 of each year. All credits must be reported by February 15 of the following year. A maximum of 12 credits, including 1 ethics credit, may be carried over for 1 year only.
Formats
