Trusts Serving as Grantors to Other Trusts: Drafting Multi-Trust Structures for Optimal Tax Results

Mr. Bunge focuses his practice on sophisticated tax and estate planning for wealthy individuals and families, including executives, business owners, entertainers, investors, multi-generational families, and their advisors. He helps clients develop comprehensive wealth transfer strategies, minimize income and estate taxes, and structure their affairs around liquidity events, business sales, and generational transitions. Mr. Bunge works extensively with families on the formation, structuring, and governance of family offices, private trust companies, and family investment entities. He has been a primary drafter of numerous amendments to Tennessee’s trust laws through the Tennessee Bankers Association Trust Law Committee, has authored or contributed to numerous articles and books, and speaks extensively on tax and estate planning topics.

Mr. Heuer focuses his practice on international income and transfer tax matters. He assists high-net-worth individuals and families throughout the world with complex tax issues arising from their ties to the United States. Mr. Heuer works with trust companies, financial advisors as well as foreign banks and lawyers on international strategies for investment within the United States and abroad. He also helps cross-border families with the preservation and transmission of their wealth. Mr. Heuer routinely provides corporate and tax advice in a wide variety of global transactional matters. This includes inbound and outbound analysis, tax treaty examination and tax-efficient structures for multinational companies. He also advises clients on cross-border mergers, acquisitions, dispositions, joint ventures, spin-offs and tax-free reorganizations. In addition, he provides counsel on the various tax reporting requirements of doing business with the United States. This includes tax compliance for foreigners with businesses and investments in the United States as well as Americans with offshore investments. Mr. Heuer drafts tax compliance memoranda and evaluates FATCA and CRS classifications and obligations. He also assists with expatriation and counsels noncompliant taxpayers through the various voluntary disclosure programs. Mr. Heuer is an adjunct professor in the LLM Tax Program at Northwestern Pritzker School of Law, where he teaches international estate planning.