TAX665 Southern New Hampshire University Estate and Gift Taxation Paper

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You are an associate in a boutique tax consulting firm that specializes in the real estate industry. You have been assigned to work with a client who needs advice on the tax implications of his business holdings, which include Skyscrapers, a commercial real estate firm organized as a sole proprietorship with a fair market value of $1 billion. He is considering transferring partial ownership of the Skyscrapers to both of his children and selling a 10% interest to an unrelated third party. Your manager has asked that you prepare a memorandum informing management of the estate and gift tax consequences of these potential transactions in addition to a cost-benefit analysis. Be sure to cite appropriate case law, statutes, and regulations in your memorandum.

1. TAX 665 Final Project Part I Milestone Two Guidelines and Rubric

You will submit a memo describing how you will incorporate trusts into the estate plan you started in Milestone One. Include a quantitative model (in Excel) explaining how the use of the trusts and the family limited partnership can reduce the family’s estate tax over time. Show how the transfer of ownership in the present via gifts or the formation of trusts will ensure a greater appreciation in value of the younger generation’s ownership interests in the family enterprise over time. Conclude whether or not the strategy is worthwhile and is ethically sound. Cite appropriate statutory authority, case law, and/or AICPA Code of Conduct or ABA Model Rules of Professional Conduct to support your conclusions.

Specifically, the following critical elements must be addressed:

I. Utilize intentionally defective grantor trusts to accomplish long-term minimization of the client’s tax liability. Consider the mechanics of these estate planning vehicles and the appropriate authority to cite.

II. Tables and Calculations: Excel Documentation

A. Consider how the strategy maximizes the amount of transferred wealth to the client’s children over time and explain the amount in an Excel spreadsheet.

B. Given the income tax consequences, conclude whether or not the strategy is worthwhile and is ethically sound. Consider justifying the strategy in comparison to an alternative transaction.

2.TAX 665 Final Project Part I Milestone Three Guidelines and Rubric

How might charitable giving impact the income, gift, or estate tax outcome for your client? Is there an optimal strategy? Recommend a charitable donation for income, gift, or estate tax planning purposes. Which deduction (income, gift, or estate) do you recommend, and why? How does life insurance impact your estate planning strategy for the client? Consider who must pay the premiums and where the cash will come from to pay premiums. Recommend an ethical compliance strategy based on the client’s comments about a valuation discount on the family limited partnership that is consistent with Internal Revenue Service (IRS) Circular 230 and the American Institute of Certified Public Accountants (AICPA) Code of Conduct. Also submit a table summarizing the estate, gift, and income tax consequences of your overall proposed estate plan over the next 24 months and how much of your client’s cash the strategy will consume.

Specifically, the following critical elements must be addressed:

I. Life Insurance, Annuity, and Charitable Giving Strategies

A. Evaluate life insurance products, annuities, and charitable giving for possible estate tax advantages in the taxable estate or in the children’s estate, while finding use of the cash flow from the sale and the real estate business. Recommend a charitable donation for income, gift, or estate tax planning purposes.

B. Recommend an ethical compliance strategy based on the client’s comments about a valuation discount on the family limited partnership that is consistent with Internal Revenue Service (IRS) Circular 230 and the American Institute of Certified Public Accountants (AICPA) Code of Conduct. Consider the client’s cash constraints, economic impact over time, IRS Circular 230, and the AICPA Code of Conduct.

C. Develop an additional ethical compliance strategy that addresses the client’s estate tax and the interest and penalty that will accrue if he does not make timely payments of tax. Acknowledge appropriate tax case law and statutes. Consider quantifying penalties and interest.

II. Tables and Calculations: Excel Documentation

A. Analyze the personal income tax consequences and value over the next 24 months as a result of the overall proposed tax strategy. Consider justifying the strategy in comparison to an alternative transaction.

 
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