Structuring Estate Freezes: Analysis with Forms

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Practice Area: Treatises, Estate Planning Brand: WG&L

Structuring Estate Freezes: Analysis with Forms
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Structuring Estate Freezes: Analysis with Forms, Second Edition is the most comprehensive, completely up-to-date authority on estate freezing. Included are all relevant IRS rulings and the text of many private letter rulings issued on Chapter 14.

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Table of Contents

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Part I: Technical Analysis
Chapter 1: Background of Chapter 14
Chapter 2: Special Valuation Rules for Transfers of Interests in Multiclass Corporations and Partnerships (Section 2701)
Chapter 3: Trusts and Term Interests (Section 2702)
Chapter 4: Buy-Sell Agreements and Similar Arrangements (Section 2703)
Chapter 5: Lapsing Voting or Liquidation Rights (Section 2704)
Chapter 6: Special Statute of Limitations (Section 6501(c)(9))

Part II: Estate Freezing Techniques
Chapter 7: Corporate and Partnership Recapitalizations
Chapter 8: Buy-Sell Agreements
Chapter 9: Outright Gifts of Interests in a Family Corporation or Partnership
Chapter 10: Grantor Retained Income (or Use) Trusts
Chapter 11: Grantor Retained Annuity Trusts and Unitrusts
Chapter 12: Estate Freezing and Reduction With Intrafamily Sales
Chapter 13: Remainder Sales and Split Purchases
Chapter 14: Circular 230 and Chapter 14

Appendix A. Selected Forms
Appendix B. Legislative and Regulatory Materials
Appendix C. Full Text of Selected IRS Private Letter Rulings Issued Regarding Chapter 14

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