[EstGift] FW: Spousal IV QTIP trust structure for installment sale to grantor trust

Wed Jul 11 16:30:18 PDT 2007

For those of you who wanted the powerpoint for Jonathan's structuring,
you can find it with the other materials for the summer committee
meeting.  Link is below.  Diana 

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From: William L. Crawford [mailto:wlcrawford at actec.org] 
Sent: Tuesday, July 10, 2007 6:50 PM
To: Zeydel, Diana (Shld-Mia-T&E)
Subject: RE: Spousal IV QTIP trust structure for installment sale to
grantor trust

Diana, 

I made a PDF of your PowerPoint and put it up at
http://www.actec.org/private/freeform/page.asp?PageID=692#EstGift

I can add it as a PowerPoint presentation too, if that's what you had in
mind.

Bill

-----Original Message-----
From: ZeydelD at gtlaw.com [mailto:ZeydelD at gtlaw.com]
Sent: Thursday, July 05, 2007 8:52 AM
To: wlcrawford at actec.org
Subject: RE: Spousal IV QTIP trust structure for installment sale to
grantor trust

That is the program.  What we need is the powerpoint.  Thanks.  Diana 

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     Tax Advice Disclosure: To ensure compliance with requirements
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From: William L. Crawford [mailto:wlcrawford at actec.org]
Sent: Thursday, July 05, 2007 11:51 AM
To: Zeydel, Diana (Shld-Mia-T&E)
Subject: RE: Spousal IV QTIP trust structure for installment sale to
grantor trust

Diana, 

Is it the one titled: Financial Analysis Meets Tax Planning: In Depth
GRAT Analysis and Comparison?

Thanks,

Bill

-----Original Message-----
From: ZeydelD at gtlaw.com [mailto:ZeydelD at gtlaw.com]
Sent: Wednesday, July 04, 2007 5:42 PM
To: wlcrawford at actec.org
Cc: jblattmachr at milbank.com
Subject: FW: Spousal IV QTIP trust structure for installment sale to
grantor trust

BIll:  Can you please add the powerpoint slide show  from the
Blattmachr/Zeydel presentation in Scottsdale to the Estate and Gift Tax
Committee materials for the Salt Lake City meeting on the webstie?  Let
me know when it is done.  Thanks.  Diana

________________________________

     Tax Advice Disclosure: To ensure compliance with requirements
imposed by the IRS under Circular 230, we inform you that any U.S.
federal tax advice contained in this communication (including any
attachments), unless otherwise specifically stated, was not intended or
written to be used, and cannot be used, for the purpose of (1) avoiding
penalties under the Internal Revenue Code or (2) promoting, marketing or
recommending to another party any matters addressed herein.

     The information contained in this transmission may contain
privileged and confidential information.  It is intended only for the
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________________________________

From: Blattmachr, Jonathan [mailto:JBlattmachr at milbank.com]
Sent: Tuesday, July 03, 2007 9:50 PM
To: RPomeroy at goodwinprocter.com
Cc: Zeydel, Diana (Shld-Mia-T&E)
Subject: Re: Spousal IV QTIP trust structure for installment sale to
grantor trust

Rob: I don't know. Diana: is it in our article? I'm happy to share it.
When
I developed the ISGT in 1991 I sworn I'd keep it secret but Arthur
Anderson squealed. I think we ought to keep the profile kind of low to
avoid IRS anxiety.  Please use it to your heart's content, altho I
wouldn't broadcast it. Jonathan

PS: I haven't patented it.

----- Original Message -----
From: Pomeroy, Robert C <RPomeroy at goodwinprocter.com>
To: Blattmachr, Jonathan
Sent: Tue Jul 03 15:04:14 2007
Subject: Spousal IV QTIP trust structure for installment sale to grantor
trust

Jon,

        Is what you  have written about this in the public domain?  If
so, could you please point me in the right direction?  Thanks.

Robert C. Pomeroy

Goodwin Procter  LLP

Exchange Place

Boston, MA 02109

(617) 570-1150

Fax (617) 523-1231

rpomeroy at goodwinprocter.com

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