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2025-08-21 12:00:00

4 Credits

LLCs in Tax and Estate Planning covers entity structuring, operating agreement drafting, freeze structures, IRS audits, asset protection, and digital assets.

2025-08-21 12:00:00

4 hours

LLCs in Tax and Estate Planning covers entity structuring, operating agreement drafting, freeze structures, IRS audits, asset protection, and digital assets.

2025-08-21 12:00:00

4 hours

1000+

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24/7

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70,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

Course Overview

Mastering LLCs for Tax and Estate Planning

Participants will learn to structure, draft, and defend LLC arrangements for optimal tax treatment, estate transfers, and asset protection. These strategies apply directly to family business succession and wealth preservation.

Key topics that will be covered

What will you learn

Attorneys will learn how LLCs evolved after check-the-box regulations, operating agreement drafting nuances, freeze structures, IRS audit considerations, asset protection strategies, and digital asset planning.

What will you gain

Attorneys will gain practical skills for structuring LLCs, navigating Section 2036 traps, drafting BBA-compliant provisions, implementing charging order protections, and planning for cryptocurrency holdings.

Entity Selection
LLCs offer partnership taxation advantages including debt basis allocation and special allocations.
Agreement Drafting
Operating agreements must match how clients actually intend to operate the business.
Estate Planning
Section 2036 presents the most significant trap in family LLC planning.
Freeze Structures
Profits interests can shift future appreciation to younger generations tax-free.
IRS Audits
The BBA centralized audit regime makes partnerships responsible for imputed underpayments.
Asset Protection
Charging order protection has numerous exceptions and should not be relied upon alone.

What will you learn

Attorneys will learn how LLCs evolved after check-the-box regulations, operating agreement drafting nuances, freeze structures, IRS audit considerations, asset protection strategies, and digital asset planning.

What will you gain

Attorneys will gain practical skills for structuring LLCs, navigating Section 2036 traps, drafting BBA-compliant provisions, implementing charging order protections, and planning for cryptocurrency holdings.

Agenda

Session 1

Foundations of LLC Use in Tax and Estate Planning

Session 2

Common Pitfalls and Essential Practice Tips for LLCs

Session 3

LLC Operating Agreement Drafting: Legal and Tax Nuances

Session 4

Income Shifting and Estate Freeze Structure Strategies

Session 5

IRS Scrutiny, Audit Risk, and Defensive Planning Strategies

Session 6

Asset Protection Through Charging Orders and Creditor Structuring

Session 7

LLCs for Digital Assets and Cryptocurrency Holdings

clock 12:00 pm - 12:30 pm EST

Foundations of LLC Use in Tax and Estate Planning

Jay D. Adkinson

Adkisson Pitet LLP

Robert S. Barnett

Capell Barnett Matalon & Schoenfeld LLP

Jeff Cunningham

Bradley Arant Boult Cummings LLP

Rustin Diehl

Allegis Law

Allen N. Bradley

Bradley Arant Boult Cummings LLP

This 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

Adkisson Pitet LLP

Robert S. Barnett

Capell Barnett Matalon & Schoenfeld LLP

Jeff Cunningham

Bradley Arant Boult Cummings LLP

Rustin Diehl

Allegis Law

Allen N. Bradley

Bradley Arant Boult Cummings LLP

clock 12:30 pm - 1:00 pm EST

Common Pitfalls and Essential Practice Tips for LLCs

Jay D. Adkinson

Adkisson Pitet LLP

Robert S. Barnett

Capell Barnett Matalon & Schoenfeld LLP

Jeff Cunningham

Bradley Arant Boult Cummings LLP

Rustin Diehl

Allegis Law

Allen N. Bradley

Bradley Arant Boult Cummings LLP

Explore 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. Adkinson

Adkisson Pitet LLP

Robert S. Barnett

Capell Barnett Matalon & Schoenfeld LLP

Jeff Cunningham

Bradley Arant Boult Cummings LLP

Rustin Diehl

Allegis Law

Allen N. Bradley

Bradley Arant Boult Cummings LLP

clock 1:10 pm - 1:40 pm EST

LLC Operating Agreement Drafting: Legal and Tax Nuances

Jay D. Adkinson

Adkisson Pitet LLP

Robert S. Barnett

Capell Barnett Matalon & Schoenfeld LLP

Jeff Cunningham

Bradley Arant Boult Cummings LLP

Rustin Diehl

Allegis Law

Allen N. Bradley

Bradley Arant Boult Cummings LLP

Master 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. Adkinson

Adkisson Pitet LLP

Robert S. Barnett

Capell Barnett Matalon & Schoenfeld LLP

Jeff Cunningham

Bradley Arant Boult Cummings LLP

Rustin Diehl

Allegis Law

Allen N. Bradley

Bradley Arant Boult Cummings LLP

clock 1:40 pm - 2:10 pm EST

Income Shifting and Estate Freeze Structure Strategies

Jay D. Adkinson

Adkisson Pitet LLP

Robert S. Barnett

Capell Barnett Matalon & Schoenfeld LLP

Jeff Cunningham

Bradley Arant Boult Cummings LLP

Rustin Diehl

Allegis Law

Allen N. Bradley

Bradley Arant Boult Cummings LLP

Learn 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. Adkinson

Adkisson Pitet LLP

Robert S. Barnett

Capell Barnett Matalon & Schoenfeld LLP

Jeff Cunningham

Bradley Arant Boult Cummings LLP

Rustin Diehl

Allegis Law

Allen N. Bradley

Bradley Arant Boult Cummings LLP

clock 2:20 pm - 2:50 pm EST

IRS Scrutiny, Audit Risk, and Defensive Planning Strategies

Jay D. Adkinson

Adkisson Pitet LLP

Robert S. Barnett

Capell Barnett Matalon & Schoenfeld LLP

Jeff Cunningham

Bradley Arant Boult Cummings LLP

Rustin Diehl

Allegis Law

Allen N. Bradley

Bradley Arant Boult Cummings LLP

Navigate 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. Adkinson

Adkisson Pitet LLP

Robert S. Barnett

Capell Barnett Matalon & Schoenfeld LLP

Jeff Cunningham

Bradley Arant Boult Cummings LLP

Rustin Diehl

Allegis Law

Allen N. Bradley

Bradley Arant Boult Cummings LLP

clock 2:50 pm - 3:50 pm EST

Asset Protection Through Charging Orders and Creditor Structuring

Jay D. Adkinson

Adkisson Pitet LLP

Robert S. Barnett

Capell Barnett Matalon & Schoenfeld LLP

Jeff Cunningham

Bradley Arant Boult Cummings LLP

Rustin Diehl

Allegis Law

Allen N. Bradley

Bradley Arant Boult Cummings LLP

Understand 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. Adkinson

Adkisson Pitet LLP

Robert S. Barnett

Capell Barnett Matalon & Schoenfeld LLP

Jeff Cunningham

Bradley Arant Boult Cummings LLP

Rustin Diehl

Allegis Law

Allen N. Bradley

Bradley Arant Boult Cummings LLP

clock 4:00 pm - 4:30 pm EST

LLCs for Digital Assets and Cryptocurrency Holdings

Jay D. Adkinson

Adkisson Pitet LLP

Robert S. Barnett

Capell Barnett Matalon & Schoenfeld LLP

Jeff Cunningham

Bradley Arant Boult Cummings LLP

Rustin Diehl

Allegis Law

Allen N. Bradley

Bradley Arant Boult Cummings LLP

Address 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. Adkinson

Adkisson Pitet LLP

Robert S. Barnett

Capell Barnett Matalon & Schoenfeld LLP

Jeff Cunningham

Bradley Arant Boult Cummings LLP

Rustin Diehl

Allegis Law

Allen N. Bradley

Bradley Arant Boult Cummings LLP

01 07
Prev
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speakers

Joe Ervin

The Law Firm for Truck Safety, LLP
A Partner at The Law Firm for Truck Safety. He focuses exclusively on cases involving commercial motor vehicle crashes and wrongful death. Joe also holds a valid class “A” commercial driver’s license with endorsements for double/triple trailers and tankers.

Education & Credentials

A 2013 graduate of the Gerry Spence Trial Lawyers College in Dubois, Wyoming, Joe is rated AV Preeminent™ by Martindale-Hubbell — the highest peer rating for exceptional legal ability and ethics. He is among the first nine attorneys nationwide to earn board certification in Truck Accident Law from the National Board of Trial Advocacy.

Recognition & Leadership

Joe received the Roadway Safety Award from the American Association for Justice (AAJ) for his commitment to improving highway safety.
 He currently serves as Co-Chair of the Academy of Truck Accident Attorneys (ATAA) Safety Committee, advocating for higher safety standards across the trucking industry.

Professional Involvement

Joe serves on the faculty of the AAJ Advanced Trial Advocacy College: Litigating Truck Collision Cases (2015 & 2024).
 He is an active member of AAJ’s Trucking Litigation Group and sits on the Board of Regents for the Academy of Truck Accident Attorneys.

Experience

Joe frequently consults and co-counsels on complex commercial truck cases. His proven track record includes numerous successful trials against motor carriers and truck leasing companies — delivering justice for victims of commercial vehicle accidents.

Kevin Foley

Reminger Co
A Partner at The Law Firm for Truck Safety. He focuses exclusively on cases involving commercial motor vehicle crashes and wrongful death. Joe also holds a valid class “A” commercial driver’s license with endorsements for double/triple trailers and tankers.

Education & Credentials

A 2013 graduate of the Gerry Spence Trial Lawyers College in Dubois, Wyoming, Joe is rated AV Preeminent™ by Martindale-Hubbell — the highest peer rating for exceptional legal ability and ethics. He is among the first nine attorneys nationwide to earn board certification in Truck Accident Law from the National Board of Trial Advocacy.

Recognition & Leadership

Joe received the Roadway Safety Award from the American Association for Justice (AAJ) for his commitment to improving highway safety.
 He currently serves as Co-Chair of the Academy of Truck Accident Attorneys (ATAA) Safety Committee, advocating for higher safety standards across the trucking industry.

Professional Involvement

Joe serves on the faculty of the AAJ Advanced Trial Advocacy College: Litigating Truck Collision Cases (2015 & 2024).
 He is an active member of AAJ’s Trucking Litigation Group and sits on the Board of Regents for the Academy of Truck Accident Attorneys.

Experience

Joe frequently consults and co-counsels on complex commercial truck cases. His proven track record includes numerous successful trials against motor carriers and truck leasing companies — delivering justice for victims of commercial vehicle accidents.

Grant H. Lawson

The Law Firm for Truck Safety, LLP
A Partner at The Law Firm for Truck Safety. He focuses exclusively on cases involving commercial motor vehicle crashes and wrongful death. Joe also holds a valid class “A” commercial driver’s license with endorsements for double/triple trailers and tankers.

Education & Credentials

A 2013 graduate of the Gerry Spence Trial Lawyers College in Dubois, Wyoming, Joe is rated AV Preeminent™ by Martindale-Hubbell — the highest peer rating for exceptional legal ability and ethics. He is among the first nine attorneys nationwide to earn board certification in Truck Accident Law from the National Board of Trial Advocacy.

Recognition & Leadership

Joe received the Roadway Safety Award from the American Association for Justice (AAJ) for his commitment to improving highway safety.
 He currently serves as Co-Chair of the Academy of Truck Accident Attorneys (ATAA) Safety Committee, advocating for higher safety standards across the trucking industry.

Professional Involvement

Joe serves on the faculty of the AAJ Advanced Trial Advocacy College: Litigating Truck Collision Cases (2015 & 2024).
 He is an active member of AAJ’s Trucking Litigation Group and sits on the Board of Regents for the Academy of Truck Accident Attorneys.

Experience

Joe frequently consults and co-counsels on complex commercial truck cases. His proven track record includes numerous successful trials against motor carriers and truck leasing companies — delivering justice for victims of commercial vehicle accidents.

Jay D. Adkinson

Adkisson Pitet LLP

Robert S. Barnett

Capell Barnett Matalon & Schoenfeld LLP

Jeff Cunningham

Bradley Arant Boult Cummings LLP

Rustin Diehl

Allegis Law

Allen N. Bradley

Bradley Arant Boult Cummings LLP

Jay D. Adkinson

Adkisson Pitet LLP

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.

Recognition & Leadership

Twice testified before the U.S. Senate Finance Committee on abusive tax practices, contributing columnist at Forbes, Honorary Member of the California Association of Judgment Professionals, nationally recognized leader in specialized legal arena.

Professional Involvement

Adviser to the Uniform Law Commission on multiple legislative projects, Honorary Member of the California Association of Judgment Professionals.

Experience

Managing Partner of the Las Vegas office of Adkisson Pitet LLP, practices out of Newport Beach, California. Has served as a court-appointed receiver, an expert on fraudulent transfers, and adviser to the Uniform Law Commission on multiple legislative projects. Authored several seminal works including The Charging Order Practice Guide (ABA) and Asset Protection: Concepts and Strategies (McGraw-Hill).

Jay D. Adkinson

Adkisson Pitet LLP

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.

Recognition & Leadership

Twice testified before the U.S. Senate Finance Committee on abusive tax practices, contributing columnist at Forbes, Honorary Member of the California Association of Judgment Professionals, nationally recognized leader in specialized legal arena.

Professional Involvement

Adviser to the Uniform Law Commission on multiple legislative projects, Honorary Member of the California Association of Judgment Professionals.

Experience

Managing Partner of the Las Vegas office of Adkisson Pitet LLP, practices out of Newport Beach, California. Has served as a court-appointed receiver, an expert on fraudulent transfers, and adviser to the Uniform Law Commission on multiple legislative projects. Authored several seminal works including The Charging Order Practice Guide (ABA) and Asset Protection: Concepts and Strategies (McGraw-Hill).

Robert S. Barnett

Capell Barnett Matalon & Schoenfeld LLP

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.

Education & Credentials

Mr. Barnett earned his Bachelor of Science degree in accounting from Hofstra University, graduating magna cum laude. He went on to receive his Juris Doctor in 1986 from Fordham University, where he graduated cum laude and served as a member of the Fordham Law Review. He also holds a Master's degree in Taxation, which he received as the recipient of the highest dean's award. In addition to his legal credentials, Mr. Barnett holds the designation of Certified Public Accountant (CPA). He is admitted to practice law in New York, Virginia, and Washington, D.C.

Recognition & Leadership

Mr. Barnett was recognized as a 2024 Top Lawyer of Long Island by the Long Island Herald. He has been selected to the Super Lawyers list from 2021 through 2025. He was named Chair of the New York State Society of CPAs (NYSSCPA) Estate Planning Committee for 2019 and 2020. He currently serves as an adjunct professor in the graduate tax program at Hofstra University and previously held that same role at Long Island University's School of Professional Accounting.

Professional Involvement

Mr. Barnett has served on many professional and charitable committees and boards throughout his career. He has lectured extensively before a wide range of organizations, including the American Bar Association, the AICPA, the New York State Society of CPAs, the Nassau County Bar Association, the National Conference of CPA Practitioners, the National Business Institute, St. John's University, Baruch College, Hofstra University, Long Island University, and numerous others. He has also delivered webinars through platforms including Strafford, Lorman, CPE Link, CPA Academy, and myLawCLE.

Experience

Mr. Barnett's practice at Capell Barnett Matalon & Schoenfeld LLP encompasses taxation, trusts and estates, corporate and commercial transactions, tax controversy, and estate administration. His hands-on experience spans Surrogate's Court proceedings, Tax Court representation, tax dispute resolution, and the structuring of financial transactions and charitable gifts. He has published articles across numerous legal and accounting publications, including the CPA Journal, the New York Law Journal, the Journal of Taxation, the Journal of Accountancy, the Nassau Lawyer, and Investment News, covering topics from passive activity losses and S corporation taxation to estate planning, charitable giving, and cryptocurrency enforcement.

Jeff Cunningham

Bradley Arant Boult Cummings LLP

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.

Recognition & Leadership

Frequently presents structuring strategies for business lawyers and CPAs, known for translating complex legal issues into practical, business-ready solutions.

Experience

Serves as outside general counsel to closely held and high-growth companies, guiding them from formation through complex transactions and eventual exit. Client base spans diverse industries including manufacturing, services, tech, and construction, including startups and multigenerational family businesses. Advises on business training, capital raising, equity design, commercial contracts, licensing, M&A, and succession planning.

Rustin Diehl

Allegis Law

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.

Recognition & Leadership

Nationally respected speaker and educator on tax, business, and estate topics.

Professional Involvement

Adjunct Professor at Weber State University teaching business law.

Experience

Regularly presents to attorneys, accountants, and financial advisors. Practice focuses on high-net-worth clients, closely held business owners, and investors seeking tax minimization and legal protection across generations. Provides strategic counsel in transactions, compliance, and long-range planning, including digital asset structuring.

Allen N. Bradley

Bradley Arant Boult Cummings LLP

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.

Experience

Transactional tax attorney assisting clients with corporate and finance transactions, corporate and partnership tax, executive and other non-qualified compensation, and trusts and estates law. Significant experience with renewable energy tax matters and negotiating contracts for solar energy projects.

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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

  • Attorneys can earn unlimited “live” credit through live seminars, live webcasts, and co-sponsored locations with MyLAWCLE-Alabama approved programs
  • Attorneys are limited to 6 credits per compliance period of “online” programs through MyLAwCLE On-Demand programs