[EstGift] Join Us In Marco Island March 4th!

[Mickey Davis]

We hope you're planning to join us in sunny and warm Marco Island!  The Estate and Gift Tax Committee will meet from 3:00 to 6:00 pm on Wednesday, March 4th. Finish off your first full day of the Annual Meeting with this great line-up of interesting topics:


  *   Planning with Portability:  Richard Franklin and George Karibjanian will describe a creative use of combining QTIP trusts, Code Section 2519, and some innovative post-mortem steps that may make portability a much more palatable tool for second-marriage clients.
  *   Perpetual Trust Pitfalls? Les Raatz will lead a discussion on the recent Vanderbilt Law Review article by Steven Horowitz and Professor Rob Sitkoff on Unconstitutional Perpetual Trusts. Hear the latest thoughts on the interplay of state constitutions and laws on the Rule Against Perpetuities.  Can a legislature bend the Rule by defining perpetuities or stretching their term? This topic is essential not only for planning with dynastic trusts, but for offensive use of the Delaware Tax Trap!
  *   Preferred and Profits-Interest Partnerships: Partnership structuring is still in vogue.  Using partnership freezes and creating profits-interest partnerships can have dramatic estate planning impacts.  Richard Dees will explore these creatures and keep us grounded in the Chapter 14 tax issues that must be a part of every partnership plan.
  *   Post-Mortem GRAT Issues:  Is there any benefit to designing a long-term GRAT, even a non-zeroed out one, if your client doesn't survive the GRAT term?  Turney Berry will discuss some recent modeling that paves a path through this perplexing area.
  *   Passing Potential Profits to Progeny:  Can a business owner effectively shift value to the objects of her bounty by allowing them to take advantage of business opportunities, without having those actions give rise to a taxable gift? Steve Akers will review three recent Tax Court decisions that show that the IRS has this issue in its sights (including a summary from the cases about what to do and not do!)
  *   Purposefully Undoing Estate Plans: Take part in our popular Open Forum and join the discussion as Barbara Sloan continues our examination of purposefully unwinding estate plans.  Prepare to ponder a panoply of practical pointers, including, dare I say, avoiding discounts and causing estate inclusion, as well as potential pitfalls to avoid as we explore specific steps to consider with clients.

If time permits, we will peruse pertinent recent developments. I'm looking forward to your attendance and participation!

Have we forgotten something?  If there's a topic you're dying to hear about or a presentation you'd like to make to the Committee, please let me know.  Planning is already under way for topics to discuss at the Summer Meeting in Quebec!


Mickey R. Davis
Davis & Willms, PLLC
Fellow, American College of Trust and Estate Counsel
Board Certified - Estate Planning & Probate Law Texas Board of Legal Specialization
3555 Timmons Lane, Suite 1250
Houston, Texas 77027
(281) 786-4502 voice
(281) 742-2600 fax
mickey at daviswillms.com<mailto:mickey at daviswillms.com>   |   www.daviswillms.com<http://www.daviswillms.com/>
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