Upcoming Events

On June 6, 2024, the U.S. Supreme Court issued a unanimous opinion on a closely held business valuation case that will have significant impact on many family and closely held businesses. Connelly v. United States, U.S., No. 23-146, Opinion 6/6/24. The case addressed the valuation of stock in a closely held business and held that the obligation of an entity to buy a deceased equity owner’s shares does not reduce the value of the insurance proceeds received by the entity to fund the buyout. The Supreme Court’s ruling resolves the conflict between the Connelly case and the Estate of Blount v. Commissioner, which had reached the opposite conclusion. What should practitioners be telling clients now? Will every redemption agreement be adversely affected? Should redemption agreements be restructured as cross-purchase agreements? Should more insurance be purchased to address potential estate taxes? How will the reduction in the exemption in 2026 exacerbate the negative repercussions of Connelly?

Because of Sunset, Spousal Lifetime Access Trusts have become one of the most commonly-used and powerful planning techniques in the planner’s toolbox. In his exclusive LISI Webinar, Bob Keebler, CPA/PFS, AEP (Distinguished), will give you all you need to know about  on planning with SLATs, including:

• Understanding the key components of a SLAT, how they work and why they’re used
• Learn how the Reciprocal Trust Doctrine works and how to avoid it
• Why SLATs are efficient even for clients who won’t be subject to the estate tax, and more importantly, even when the unified credit is cut in half
• Why is it important to mix and match techniques like SLATs, DAPTs, hybrid DAPTs, and SPATs to get the best results for your clients?
• Understanding when a SLAT is taxed versus being disregarded and when to “toggle off” grantor tax status
• What are the most critical considerations for ensuring that clients maintain control/access to their trust assets
• Commons traps for the unwary in these commonly used trusts
• Common risk management and compliance issues that must be considered when using these trusts with clients
• Choosing the right situs and trustee
• Funding considerations and asset protection considerations
• Critical case studies that demonstrate all of the concepts mentioned above

Who should take this class? CPAs, attorneys,  financial planners and other professional financial planners who regularly deal with estate planning, tax and retirement planning issues.

The paradigm shift from life expectancy distributions to a 10-year distribution is at its core a mathematical problem. Therefore, quantitative driven strategies can mitigate the impact of lost deferral. These strategies include Roth conversions, life insurance, and utilizing charitable remainder trusts.

Moreover, tried and true strategies to mitigate built-in income tax consequences of “inherited” IRAs gain importance with a 10-year rule. For example, state tax-exempt IRA trusts along with tactical planning at both the beneficiary designation form level and the trust level.

In any case, there is a critical need for lawyers, CPAs and planners to understand the mathematics. This is not a class designed to help wealthy clients, but rather will provide advice for the mass-affluent. Properly applied these strategies will provide tremendous value and demonstrate expertise.

The paradigm shift from life expectancy distributions to a 10-year distribution is at its core a mathematical problem. Therefore, quantitative driven strategies can mitigate the impact of lost deferral. These strategies include Roth conversions, life insurance, and utilizing charitable remainder trusts.

Moreover, tried and true strategies to mitigate built-in income tax consequences of “inherited” IRAs gain importance with a 10-year rule. For example, state tax-exempt IRA trusts along with tactical planning at both the beneficiary designation form level and the trust level.

In any case, there is a critical need for lawyers, CPAs and planners to understand the mathematics. This is not a class designed to help wealthy clients, but rather will provide advice for the mass-affluent. Properly applied these strategies will provide tremendous value and demonstrate expertise. Learn More.

On June 6, 2024, the U.S. Supreme Court issued a unanimous opinion on a closely held business valuation case that will have significant impact on many family and closely held businesses. Connelly v. United States, U.S., No. 23-146, Opinion 6/6/24. The case addressed the valuation of stock in a closely held business and held that the obligation of an entity to buy a deceased equity owner’s shares does not reduce the value of the insurance proceeds received by the entity to fund the buyout. The Supreme Court’s ruling resolves the conflict between the Connelly case and the Estate of Blount v. Commissioner, which had reached the opposite conclusion. What should practitioners be telling clients now? Will every redemption agreement be adversely affected? Should redemption agreements be restructured as cross-purchase agreements? Should more insurance be purchased to address potential estate taxes? How will the reduction in the exemption in 2026 exacerbate the negative repercussions of Connelly?

Roth conversions have always had the potential to unlock hidden value. However, 2024 may be an especially effective year to consider a conversion as many marginal tax rate increases seem to be clearly on the horizon along with significant changes to conversion and accumulation rules. Should there be substantial market volatility the timing may be near perfect.

Moreover, SECURE 2.0 expands the impact of Roth conversions beyond a quantitative arbitrage game to a strategic estate planning issue. Therefore, quantitative driven strategies can mitigate the impact of lost deferral and Roth conversions will be the primary tool for most families.

Specifically, this webinar will cover the following topics:

• Low value Roth conversions
• Repaying coronavirus-related distributions to a Roth Account
• Critical Roth conversion concepts after SECURE
• 10+ Reasons to convert to a Roth IRA
• Taxation of Roth IRA conversions and distributions
• Easy to read conversion tables by common scenarios
• Mathematics of Roth IRA conversions
• Timing of Roth IRA conversions to gain tax rate arbitrage
• Estate tax considerations and why a Roth conversion is much better when an estate tax exists
• Hedging Roth conversions with life insurance
• Using insurance to preserve post-death “stretch-out”

In his exclusive LISI Webinar, Bob Keebler will cover:

Overview of Key Considerations

• Income, Estate and Gift Taxes
• Generation Skipping Transfer Taxes
• Income §691(c) Deduction and Its Failures
• State Estate Taxes
• State Income Taxes

Overview of SECURE

• 10-Year Rule
• Exception Beneficiaries

Roth Conversions

• The SECURE Act’s ten-year payout rule and the high tax rates to follow
• What the Lawyer needs to know about the strategic aspects of conversions and Estate Planning Benefits
• 2021 Roth Update with Higher Income and Estate Rates
• Critical Roth conversion concepts after SECURE
• Roth conversions for rate arbitrage compared to traditional IRAs to trusts
• 10+ Reasons to convert to a Roth IRA
• Estate tax considerations
• Why a Roth conversion is much better when an estate tax exists
• “Stretch” Roth IRAs for eligible designated beneficiaries
• Roths for SNTs and asset protection trusts
• Using insurance to preserve post-death “stretch-out”
• Why a conversion is a “Bet-to-Live” Strategy and why insurance is a “Bet-to-Die” Strategy
• Easy to read charts, graphs and tables

Charitable Remainder Trust Strategies

• How IRA-CRTs can simulate the longer payout and still benefit charity
• Understand the Mathematics of the IRA-CRT with and without an estate tax
• Understanding the income tax aspects of CRTs
• Converting ordinary income to long-term capital gains
• Designing IRA CRTs for spouses with a 100% marital and charitable estate tax deduction
• Designing IRA CRTs for children and grandchildren including GST issues
• The reasons why the IRA-CRT is a better decision now more than ever and why insurance planning compliments CRT planning
• Running the numbers to compare strategies and why the CRT really works for charitably inclined clients
• Why the 691(c) deduction fails to truly benefit the beneficiaries

Insurance Strategies

• Powerhouse Life Insurance Strategies
• Understand the Income and Estate Tax-Free Benefits of IRA relocation (i.e., utilizing IRA distributions to Purchase Life Insurance)
• Learn Advanced Insurance Strategies Including Policy Designs to Maximize ROI
• Debt financed life insurance strategies

State IRA Income Tax Strategy Trusts

• Which “home” states allow this strategy
• How the SCOTUS opinion in Kaestner may impact this strategy
• How the Minnesota Supreme Court opinion in Fielding impacts this strategy
• How DNI transfers income from a trust to beneficiaries equally
• The throwback rules of California and New York
• Tax treatment of capital gains after IRA withdrawals from both regular and Roth IRAs

Multi-generational Accumulation Trust Sprinkling

• The operation of the DNI Rules of Subchapter J which allow you to shift income
• The 65-Day Rule
• Why 10 years is really 11 tax years
• State law fiduciary accounting income issues
• State income tax issues
• The math of sprinkle trust strategies
• When charities can (in some cases, should?) be added and why

In this class Bob Keebler will review the following:

• The use of charitable remainder trusts to defer and eliminate capital gains
• The use of § 453 installment sales to reduce capital gains and how to elect out of installment sale treatment to accelerate gains into 2025
• The Math of recognizing capital gains in 2024
• Grantor charitable lead trusts to decrease capital gains
• Direct charitable gifts to reduce capital gains
• Opportunity zones to more effectively manage capital gains
• Integrating loss harvesting in an overall capital gains strategy
• Using 1031 exchanges to ease capital gains
• The use of collars, variable forward sales and options to better manage capital gains
• IRC § 1259 “choking” collar to trigger capital gains in 2024 or defer to a future date
• “Short against the box” strategies to choose between recognizing gains in 2024 or 2025

In this class Bob Keebler will review the following:

• The use of charitable remainder trusts to defer and eliminate capital gains
• The use of § 453 installment sales to reduce capital gains and how to elect out of installment sale treatment to accelerate gains into 2025
• The Math of recognizing capital gains in 2024
• Grantor charitable lead trusts to decrease capital gains
• Direct charitable gifts to reduce capital gains
• Opportunity zones to more effectively manage capital gains
• Integrating loss harvesting in an overall capital gains strategy
• Using 1031 exchanges to ease capital gains
• The use of collars, variable forward sales and options to better manage capital gains
• IRC § 1259 “choking” collar to trigger capital gains in 2024 or defer to a future date
• “Short against the box” strategies to choose between recognizing gains in 2024 or 2025

Because of Sunset, Spousal Lifetime Access Trusts have become one of the most commonly-used and powerful planning techniques in the planner’s toolbox. In his exclusive LISI Webinar, Bob Keebler, CPA/PFS, AEP (Distinguished), will give you all you need to know about  on planning with SLATs, including:

• Understanding the key components of a SLAT, how they work and why they’re used
• Learn how the Reciprocal Trust Doctrine works and how to avoid it
• Why SLATs are efficient even for clients who won’t be subject to the estate tax, and more importantly, even when the unified credit is cut in half
• Why is it important to mix and match techniques like SLATs, DAPTs, hybrid DAPTs, and SPATs to get the best results for your clients?
• Understanding when a SLAT is taxed versus being disregarded and when to “toggle off” grantor tax status
• What are the most critical considerations for ensuring that clients maintain control/access to their trust assets
• Commons traps for the unwary in these commonly used trusts
• Common risk management and compliance issues that must be considered when using these trusts with clients
• Choosing the right situs and trustee
• Funding considerations and asset protection considerations
• Critical case studies that demonstrate all of the concepts mentioned above

Who should take this class? CPAs, attorneys,  financial planners and other professional financial planners who regularly deal with estate planning, tax and retirement planning issues.

Family Issues and Goals

1. Understanding the State Property Law Issues
   1. Community Property Issues
   2. Forced Share Rights
   3. State Law UPIA
   4. Marital, prenuptial and postnuptial agreements
2. Role of ERISA
3. Role of THE RETIRMENT EQUITY ACT (“REA”)
4. Estate Tax Issues
   1. Federal Taxation
   2. State Taxation
5. Analysis of the Post-Mortem IRA Rules
   1. Qualified Plans
   2. IRAs
   3. Roth IRAs
6. Role of the Special EBD rules
7. Role of SECURE 2.0 – Act Section 327
8. Understanding the danger of a conduit trust
9. Analysis of State Law and UPIA
   1. What is Income?

i.      10% Rule

ii.        4% Rule

iii.      Traditional Income Rule

11. Fiduciary Income Tax Issues
    1. Taxation of IRA Distributions

i.      Traditional IRAs

ii.      Roth IRAs

iii.      Role of Basis

iv.      Taxation of NUA and Employer Securities

11. 2. How are Trust Distributions Taxed?
    3. How is Trapped Income Taxed
12. Best Creative Ideas
    1. The CRT for a Second Spouse
    2. Life insurance Trust for Spouse
    3. Roth Conversions During Marriage
    4. Out of State Trust Planning
    5. QTIP Trust to Reduce Estate Tax
    6. Portability Opportunities

Clients depend on you to solve portability issues and find curative solutions when portability was not properly addressed at first death.

In this practical and fast-paced seminar, Robert S. Keebler CPA/PFS, MST, AEP will address the distinct methods of obtaining portability including curative returns pursuant to Revenue Procedure 2022-32 and curative corrections pursuant to obtaining IRC §9100-3 relief.

Since portability became law in 2011, Bob has helped over 100 families with portability issues including curative returns and over 50 curative corrections via the private letter ruling process. In this class Bob will address the practical aspects of filing “abridged” estate tax returns at the first death when property is passing to a surviving spouse. He will also address filing for portability when a bypass trust is partially funded. Learn More.

In his exclusive LISI Webinar, Bob Keebler will cover:

Overview of Key Considerations

Overview of SECURE

Roth Conversions

Charitable Remainder Trust Strategies

Insurance Strategies

State IRA Income Tax Strategy Trusts

Multi-generational Accumulation Trust Sprinkling

Learn More Details Here.

In this fast-paced webinar Bob Keebler will present a summary of California’s new fiduciary income tax law requiring incomplete trusts to be taxed in California as a California grantor trust.

This is must-have information for all California, Alaska, Delaware, Nevada, South Dakota and Wyoming trust officers, CPAs and trust and estate lawyers.

Bob will address precisely what the Bill does and solutions, including:

• Overview of prior California law and Federal law.
• Overview of the new statute.
• The election to be treated as a California “nongrantor trust.”
• No free lunch on earlier “throwback years.”
• The use of completed gift trusts to avoid the reach of the California law.
• The use of charitable remainder trusts to defer Federal and California Tax.
• Transferring property from existing INGs to completed gift trusts.
• Selling property from INGs to completed gift trusts via IRC § 453 installment sales.
• Using life insurance and other tax shelter strategies.
• Other ideas to mitigate California’s attempt to checkmate the ING strategy.

There have been changes in estate, tax, income, and retirement planning laws coming for a while now and it is more imperative than ever for estate planners to stay on top of these changes. Includes: Monthly bulletin sent via e-mail (approximately the third week of the month). Subscribe for $49 per month.

Most estate planning professionals are already very well aware that the SECURE Act brought with it some of the biggest changes to IRA planning for clients than we have seen during our lifetime. That’s why it’s so important as estate planners that we have what we need to understand the SECURE Act and what you need to know to properly advise your clients.

This is why we, as we have in the past, have teamed up with nationally renowned CPA and IRA expert, Robert S. Keebler, to break it down for you so that you don’t have to do it yourself. Subscribe to the Printable EBook. (Includes: Downloadable, printable PDF e-Book. Pages 108.)