Income and Transfer Tax Planning for Negative Capital – The Entity Freeze Solution

Stephen M. Breitstone, head of Meltzer Lippe’s Wealth Preservation & High Net Worth Practice Group, is the author of a white paper entitled “The Entity Freeze Solution: Income and Transfer Tax Planning for Negative Capital.”

Entity freezes are an often overlooked method of shifting wealth without tax friction. This type of wealth shift can avoid income, estate, gift or generation skipping taxes. However, the entity freeze must be used in the appropriate circumstances for it to work efficiently.

Topics discussed in this 58-page White Paper include:

History of the Entity Freeze
Comparison of Entity Freezes with Alternative Freeze Techniques
Income Tax Challenges of GRAT’s and IDGT’s
Freeze Partnerships for Leveraged Low Basis Real Estate Investments
Planning with Grantor Trusts
Grantor Trusts – Death of the Grantor
Partnership Freeze Solution
Elements of the Freeze Partnership under Section 2701
Structuring the Freeze Partnership: The Forward Freeze
Special Valuation Challenges Under Section 2701 Regulations
Income Tax Consequences of the Partnership Freeze
Contributions of Low Basis Leveraged Real Estate to a Partnership
Allocations of Partnership Liabilities
Allocations of Nonrecourse Debt
Coordinating Sections 704(c) and 752
Rules Governing Disguised Sale of Property Under Section 707(a)(2)(B)
Impact of Borrowings on Disguised Sale Treatment
Valuation Considerations
Transactional Structures

You can read the complete text of this White Paper by clicking the PDF icon below.

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