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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Estate Planning

Date & Time
  • event Date

    Friday, May 17, 2024

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    90 minutes

Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$297.00
CLE
CPE
ALL

This CLE/CPE webinar will provide trusts and estates counsel guidance on utilizing Graegin loans to minimize estate taxes and potential limitations stemming from recent IRS regulations. The panelist will discuss recent developments and IRS guidance, review requirements under current tax law, and offer planning strategies to minimize estate taxes with Graegin loans.

Faculty

Lawrence M. Lipoff
Director
CohnReznick LLP

With more than 30 years of experience, Mr. Lipoff specializes in the delivery of domestic and international private client services to enable high-net-worth individuals and families to maximize their new or generational wealth. He provides strategic advice to his clients and their closely held businesses in the areas of income tax planning and compliance, estate planning and administration services, as well as family structure consulting. Through many years in practice, he synthesized the work of various related professionals, and their firms integrate several planning strategies into solutions that maximize value. Mr. Lipoff is a frequent lecturer and author of articles published through professional forums on topics including domestic and international - estate planning and fiduciary income taxation including constructive attribution rules for foreign trusts, Forms 3520 & 3520-A, Graegin Loans, business succession, generation-skipping transfers, Chapter 14 and carried interest estate planning for private investment fund principals, preferred freeze partnerships, and private placement life insurance.

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Sahri Zeger
Principal
CohnReznick LLP

Ms. Zeger, JD, MBA, leads CohnReznick’s Trust & Estates group. She has more than 20 years of experience as a tax attorney and trusted advisor to high-net-worth individuals and successful business owners. Ms. Zeger provides expertise in address the wealth preservation, estate planning, and business succession goals of our private clients, developing sophisticated tax strategies and multi-generational estate plans to meet their business, family, and charitable goals. She has comprehensive technical knowledge of estate and gift reporting rules, as well as extensive experience in identifying exposure points. Ms. Zeger is based in the Boston office.

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Description

Graegin loans can provide estates the ability to defer and reduce estate tax liability. Estate planners must understand the requirements under current tax law when utilizing Graegin loans, pitfalls to avoid, and potential limitations under recent IRS regulations.

For low liquidity estates, a Graegin loan can be used as a mechanism to finance payment of estate tax and administration expenses. Rather than selling one or more illiquid assets to pay an estate tax, the estate may borrow cash through a Graegin-style loan. The loan can finance estate tax liability and defer cash payments if structured correctly. In addition, interest payments made over the term of the loan can be deductible, further reducing estate tax liability, especially for estates that would not otherwise qualify for estate tax deferral under IRC Section 6166.

To qualify for an interest deduction, the loan must be structured to comply with IRC Section 2053 and related regulations, which allows for the deduction of administration expenses from the value of the gross estate that are "actually and necessarily" incurred in the administration of the estate. However, recent IRS regulations appear to provide significant limitations regarding the use of Graegin-style loans and the tax benefits they provide.

Listen as Benjamin Lavin, Attorney at Katten Muchin Rosenman, discusses recent developments and IRS guidance, outlines requirements under current tax law, and offers planning strategies to minimize estate taxes with Graegin loans.

Outline

  1. Graegin loans under current tax law
  2. Recent IRS regulations
  3. Structuring Graegin-style loans
  4. Best practices for trusts and estate attorneys

Benefits

The panelist will discuss these and other key issues:

  • How can Graegin-style loans be used to reduce estate tax liability?
  • What are the requirements under current tax law?
  • What pitfalls must be avoided when structuring Graegin loans?
  • What is the impact of recent IRS regulations?

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Ascertain how Graegin-style loans can be used to reduce estate tax liability
  • Understand the tax treatment and benefits of utilizing Graegin-style loans under current tax law
  • Identify key tax considerations in structuring Graegin loans for estate planning
  • Recognize the impact of recent IRS regulations on the deductibility of interest payments for estate tax purposes

  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite: Three years+ business or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of estate, gift and trust taxation including various trusts types, the unified credit, and portability.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).