Our attorneys use their talent and experience to help clients translate their desires into a clear and understandable disposition of their property, which often includes the minimization of taxes, protection of assets from creditors, and misuse by family members. Drawing from a depth of experience that stems from our diverse clientele, our attorneys are able to develop customized, efficient solutions for the various issues that our clients face. We ensure that our clients fully understand how the plan will work, both during life and at death, and we provide guidance to future generations regarding the implementation of the plan when desired by our clients.
Represented a client in the creation of a GST exempt trust of which a relative of the client was the grantor and the client was the beneficiary. The trust was designed to be a “grantor trust” for income tax purposes. Jackson Walker’s client subsequently sold the company to this trust for a $60 million promissory note, the sales price being set by the opinion of a qualified appraiser. The company was later sold for about $110 million. The proceeds were collected by the GST exempt trust to be held for the benefit of Jackson Walker’s client. The trust used $60 million (plus interest) to pay the note owed to the client while the remaining $50 million was retained by the trust and should avoid estate tax at the client’s death. If the estate tax rate is 35%, the client’s estate tax savings is $17.5 million.
Represented an estate in the U.S. Tax Court with respect to the valuation of several properties owned by the decedent through partnerships. The case involves arguments over the fair market value of the partnership interests and whether lack of control of marketability discounts should apply.