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HECKERLING REPORT

Heckerling Report #6, #7, and #8 - Wednesday Afternoon

Heckerling Report 6, Wednesday Afternoon Special Sessions, consists of:

  • “Splitting, Splicing and Stacking Strategies to Add Octane to Trust Structures,” by Diana Zeydel, Todd Angkatavanich, and Jonathan Blattmachr
  • “A Treasure Trove of Planning Tips for Foreign Assets,” by Michelle Graham, Ruth Mattson, and Suzanne Shier

Heckerling Report 7, Wednesday Special Session I-B, was “Review of the Past Year’s Significant, Curious, or Downright Fascinating Fiduciary Cases,” Dana G. Fitzsimons, Jr.

 

Heckerling Report 8, Wednesday Special Sessions, consisted of

 

  • “Three (or Thirty!) Steps in Hopes of Avoiding the Third Rail in SLAT Planning,” by Stephanie Loomis-Price, James Dougherty and Tony McCormick
  • “Choices and Challenges of CRTs: Planning with Charitable Remainder Trusts,” Kelly Hellmuth, Greg Baker, and Stevie Casteel
  • “Law Considerations in Estate Planning for Married Couples: Navigating the Ethical Minefield,” by Bruce Stone, Prof. Elizabeth Carter, and Scott Rubin

 

“Splitting, Splicing and Stacking” discussed split purchases, sales of remainder interests, split purchase GRATs, sales to grantor trusts, GRAT ETIP disadvantage, remainder purchase marital trust, ways to move from less favorable trusts to more favorable trusts, and preferred partnerships.  It’s a good discussion of a variety of ideas.

 

The report on planning tips for foreign assets report is a thorough discussion of various issues by international estate planning experts.  It’s so thorough that I have nothing to add.

 

Dana’s list of fiduciary cases is always interesting, but I didn’t glean any planning pointers to emphasize to you.

 

The SLAT special session expanded upon the plenary session and provided a lot of great tips for SLATs – worth careful study.  They recommended a grantor trust reimbursement clause.  I’m less than thrilled about doing that, because a pattern of reimbursing the grantor can trigger § 2036.  I prefer to give a special trustee the power to distribute for the spouse beneficiary’s welfare/best interests, and then taxes are taken care of when they file a joint return.

 

The CRT report is quite thorough – an excellent list of not only issues but also helpful tips.

 

The ethics panel is an excellent overview and included tips for SLATs.

 

Steve

 

Steve Gorin

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