Designed and implemented pre-IPO estate planning that used GST-tax exempt trusts, GRATs and other grantor trusts funded with carried interests in LLCs as well as traditional LLC interests. Worked extensively with real estate attorneys, securities attorneys, lenders, investment bankers and accountants to design an estate plan that would not interfere with the proposed IPO.
Prior to sale of French company owned through U.S. limited partnerships and LLCs, established GRATs to benefit children and a CLUT with the family foundation receiving the lead interest and a GST-exempt trust receiving the remainder. Worked with French attorneys and IRS to obtain reduced tax withholding rates for GRATs under U.S.-French Income Tax Convention.
Helped U.S. beneficiary reduce income taxes after becoming successor beneficiary of foreign non-grantor trusts with decades of undistributed net income, as well as investments in foreign corporations that constituted PFICs, CFCs and/or FPHCs for U.S. income tax purposes.