Nicholas Guerra, Esq. is an associate in the Tax, Trusts and Estates Department, representing high net worth individuals, families and business owners. Nicholas creates business succession and estate transfer plans designed to preserve wealth, minimize taxation and enhance family relationships. To accomplish these goals, Nicholas assists clients in the establishment of protective entity structures, charitable trusts, dynasty trusts, life insurance trusts, foreign and domestic asset protection trusts, and leveraged gifting transactions. Before joining the firm, Nicholas worked for two Am Law 100 law firms representing actors, directors, writers and producers residing in Los Angeles, CA, start-up companies located in Silicon Valley, CA and hedge fund managers residing in New York, NY. Nicholas earned his B.A. in Accounting from the University of Florida Fisher School of Accounting in 2005, his J.D. from the University of Florida Levin College of Law in 2007 and his LL.M. in Estate Planning from the University of Miami School of Law in 2009. Nicholas is admitted to practice law in Florida, New York and California.
Gifts to Irrevocable Trusts: New IRS Rules You Need to Know
Re-Broadcast on November 21, 2017
This class will enable attorneys to design new sophisticated trusts—the attorney will be able to structure a particular trust as a completed gift trust to minimize estate tax inclusion, as an incomplete gift trust to avoid current gift taxes, as a grantor trust to obtain income tax neutrality, and/or as a non-grantor trust to avoid subjecting the income of the trust to state income tax. This class will also teach attorneys to point out tax minimization strategies to clients, including the use of distributions to reduce overall income taxation, and will teach attorneys how to achieve the creditor protection benefits of an asset protection trust that are required to minimize state income taxation.
Key topics to be discussed:
• New Gift Tax IRS Private Letter Ruling: Key Lessons and Takeaways
• Trustee Taxable Income: When are Trust Income, Deductions and Credits Included?
• When are Grantors Trust Owners: Analyzing Key IRS Rules
• Completed Gifts: Clarifying Gift Tax Obligations
• Committee Distributions to Beneficiaries: When Are They Subject to Federal Gift Tax?
• General Powers of Appointment: When Committee Members Do and Don’t Have Them
Date / Time: November 21, 2017
• 2:00 pm – 4:00 pm Eastern
• 1:00 pm – 3:00 pm Central
• 12:00 pm – 2:00 pm Mountain
• 11:00 am – 1:00 pm Pacific
Choose a format:
• Live Video Broadcast/Re-Broadcast: Watch Program “live” in real-time, must sign-in and watch program on date and time set above. May ask questions during presentation via chat box. Qualifies for “live” CLE credit.
• On-Demand Video: Access CLE 24/7 via on-demand library and watch program anytime. Qualifies for self-study CLE credit. On-demand versions are made available 7 business days after the original recording date and are view-able for up to one year.
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Section I. New Gift Tax IRS Private Letter Ruling: Key Lessons and Takeaways
a) Discussion of key points
b) What are the state specific benefits of a DING/NING (Delaware/Nevada Incomplete Gift Non-Grantor Trust)
c) Why an asset protection trust is required to achieve these benefits
Section II. Trustee Taxable Income: When are Trust Income, Deductions and Credits Included?
a) How trusts are taxed
b) Strategies to minimize overall income tax
Section III. When are Grantors Trust Owners: Analyzing Key IRS Rules
a) Benefits of being treated as owner
b) Benefits of avoiding grantor trust status
c) Triggers within trusts that cause the grantor to be taxed on trust income
Section IV. Completed Gifts: Clarifying Gift Tax Obligations
a) Benefits of completed gifts
b) Benefits of incomplete gifts
c) How to design trust to avoid estate inclusion of the assets in the trust
d) How to design trusts to avoid immediate gift taxes on transfers
Section V. Committee Distributions to Beneficiaries: When Are They Subject to Federal Gift Tax?
a) When distributions are subject to gift tax
b) How to avoid gift tax on distributions
Section VI. General Powers of Appointment: When Committee Members Do and Don’t Have Them
a) Benefits and detriments of general powers of appointment
b) How to achieve a general power of appointment
c) How to avoid a general power of appointment