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Taxation and Estate Planning
Our estate planning
team provides solutions in the design, drafting and implementation of
complex wills, trusts, family partnerships, limited liability companies and
all significant personal planning techniques. We offer tax counseling in
selecting, forming and operating charitable entities, business transactional
structuring, and tax structuring for compensation issues.
Toward the goal of
asset preservation and protection, we advise professionals and others
concerned about personal liability and assist in the implementation of asset
protection techniques. Our team has extensive experience in developing and
implementing unique off-shore and on-shore plans and strategies, including
various off-shore trust structures.
Our attorneys have had
continued success in representing clients in civil tax matters before the
Internal Revenue Service and various states’ taxing authorities. We maintain
a significant practice in the administration of estates and trusts, have
successfully represented clients in substantial will contests, and continue
to advise clients on controversies in the area.
The Chair of this
department, Anthony F. Vitiello, was named to Worth magazine’s
December
2005–2008
editions “Top 100 Attorneys” list of the top lawyers nationwide specializing
in trust and estates, philanthropy, elder care, matrimonial and other
private practice areas.
In recent matters,
attorneys in the group:
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Provided
advice relating to, and implemented, estate plans for estates and
trusts ranging in value from five million dollars to more than one
billion dollars; |
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Transferred
closely held businesses to younger generations at significantly
discounted values; |
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Provided
significant asset protection advice to clients with creditor
sensitivity, ranging
from
professionals with the potential for future creditor risk to
multinational families (and their trusts) seeking to ensure the
insulation of vast multi-generational fortunes from a host of
potential risks; |
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Provided
advice concerning, and implemented, various charitable giving
techniques for clients’ estate plans, including significant family
foundations ranging in initial funding from less than $1,000,000 to
over $10,000,000; |
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Successfully defended against numerous audits and civil tax
prosecutions including: settled a tax litigation where the Internal
Revenue Service asserted in excess of twenty million dollars in gift
tax liability, penalties and interest for less than $300,000;
negotiated a settlement with the California taxing authority
involving more than $5,000,000 in income tax, penalties and interest
for $200,000; negotiated a settlement with the Internal Revenue
Service that allowed a taxpayer charged with a civil tax fraud
deficiency in excess of $600,000 to pay 15 cents on the dollar;
successfully settled numerous family partnership/LLC gift and estate
tax audits for substantial discounts; |
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Designed
multiple private and third-party insurance premium financing
transactions ranging from ten million dollars to over one hundred
million dollars in insurance death benefit; |
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Developed
and implemented various off-shore asset protection trusts using
Bahamian, Cook Islands and Swiss structuring components; |
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Successfully leveraged tens of millions of dollars of real estate
value out of a senior generation’s estate into dynasty trusts for
multi-generational wealth transfer; |
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Advised
multinational estate planning clients on various aspects of estate,
income and gift taxation, implemented estate plans for individuals
with international estate planning issues and created structures for
the avoidance of U.S. estate tax consequences for non-resident
aliens with U.S. estate tax issues; and |
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Represented
and advised hundreds of executors and families in the administration
of decedents’ estates, including those with multi-state and
multi-national issues, unique, varied and substantial assets and
complex tax and non-tax issues. |
Contact: Anthony F. Vitiello
Partners/Counsel:
Daniel B. Kessler
Kenneth F. Kunzman
Jason E. Marx
Brad D.
Shalit
Karin I.
Spalding
Anthony F. Vitiello
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