Estate and Gift Tax Planning
- Representation of the estate of the majority owner of an Iowa-based bank holding company in IRS audit proceedings and subsequent sale of the estate's stock holdings to an employee stock ownership trust ("ESOT").
- Representation of two minority shareholders in overturning a $1 million gift tax deficiency assessment in a proceeding before the Internal Revenue Service's Appellate Division
- Representation of majority shareholders and senior management of a large regional transportation company in the design and execution of a series of intergenerational transfers designed to convey approximately one-third of the company's non-voting stock to an unaffiliated holding company for the benefit of the shareholders' children.
- Representation of the owners and senior management of a $20 million manufacturing company in the design and implementation of a hybrid gift and sale of forty percent (40%) of the company's net equity to those children who actively manage the family business.
- Representation of the owners of approximately $30 million worth of commercial and residential real estate in the creation of a series of family-controlled entities to own and manage the family's real estate investments, resulting in potential transfer tax savings of approximately $10 million.
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