Once Removed Episode 19: The Step-Transaction Doctrine and the Case of Smaldino
Once Removed Episode 18: The Reciprocal Trust Doctrine
Charitable Planning With Guest Stephanie Hood: Navigating Complex Rules and Traps for the Unwary
Once Removed Episode 16: Gift and Estate Tax, Inflation Adjustments for 2024
Once Removed Episode 17: Annual Gifting to Individuals: Options, Opportunities and Pitfalls
Once Removed Episode 12: SLATs and the Case of McKim vs. McKim
Once Removed Episode 11: Spousal Lifetime Access Trusts, or SLATs
Once Removed Episode 10: Trustee Removal and Case Update on Leo Kahn Revocable Trust
(A)ESOP's Fables - The Income and Estate Tax-Free ESOP
The Renoir Spelling Bee
Taking the Sting Out of Death Taxes with Dylan Metzner, Jones & Keller
RETURN TO FOREVER - What Game Shall We Play Today?
To Give or Not to Give: Considerations for Year-End Gifting
INTRODUCING MALTA SPLIT DOLLAR
THE PAPER CHASE
With a Little Help from My Friends
The Greatest Gift: Your Individual + Family Estate Plan
Experienced trusts and estates attorneys consistently observe how proper planning can mean the difference between a thriving legacy and a fragmented enterprise. For family-owned life insurance businesses, the stakes are...more
For ultra-high-net-worth individuals (UHNWIs) whose estates far exceed the 2025 federal lifetime exemption of $13.99 million per person, the stakes for estate and asset protection planning have never been higher-or more...more
The focus of this article illustrates why private placement life insurance (“PPLI”) is the best asset to utilize in the “Buy, Borrow and Die” strategy for high net worth investors including billionaires. After this article,...more
In our previous blog post on the 2025 Heckerling Institute on Estate Planning, we highlighted the concept of purpose trusts, a conference topic involving unique planning and charitable opportunities. In this second post of...more
In the Soundtrack of Our Lives, one of the songs that I still get to hear from time to time on Sirius XM, is “Still the One” which was recorded and released by the band Orleans in 1976. I was in the tenth grade just to be...more
Litigation attorneys have had the ability to defer contingency fees since 1994. You are hard pressed to find another profession that has this tax advantage. Hedge fund managers have been running and winning the “Death Race”...more
The use of private placement life insurance (PPLI) by high-net-worth individuals has generated considerable controversy over the years, with proponents arguing that it is a proper use of existing laws that provide many of the...more
Recently, the U.S. Supreme Court ruled unanimously in Connelly v. United States, that the valuation of a decedent’s shares in a closely held corporation for federal estate tax purposes must include insurance proceeds received...more
In Connelly vs. United States (602 U.S. 257, June 6, 2024), the Supreme Court unanimously ruled that in a redemption of a deceased shareholder’s shares of stock, the corporation’s fair market value should include the proceeds...more
The US Supreme Court recently issued a significant decision, impacting many closely-held businesses with buy-sell agreements funded by life insurance policies, Connelly v. United States, 144 S. Ct. 1406 (2024). In a 9-0...more
Most closely held businesses, whether organized as a C or S corporation, LLC or partnership, have (or should have) a buy-sell agreement. A buy-sell agreement addresses what happens to an owner’s interest in the business when...more
Improperly structured buy-sell agreements for closely held businesses will lead to an unexpected increase in the estate tax imposed on the estate of the deceased owner. The Supreme Court decision emphasizes the need for a...more
On June 6, 2024, the Supreme Court of the United States issued a unanimous decision in Connelly v. United States and found that life-insurance proceeds payable to a closely held business for the purpose of funding a share...more
On June 6, 2024, the Supreme Court held 9-to-0 in Connelly v. United States that company-owned life insurance increases the company’s fair market value for estate tax purposes, and the company’s obligation to redeem a...more
The Supreme Court’s recent decision in Thomas A. Connelly et al. v. United States has significant implications for certain closely held business owners. The decision is important especially for those with, or planning to buy,...more
Many closely held businesses have shareholder buy/sell redemption agreements. These agreements are critical to maintaining business continuity when a key shareholder exits the company. When the redemption agreement is...more
On June 6, 2024, the Supreme Court unanimously decided the case of Connelly v. United States, which concerned the valuation of a business with company-owned life insurance. In this case, two brothers were the sole...more
On June 6, 2024, the U.S. Supreme Court issued a unanimous decision in Connelly v. United States affecting the valuation of closely held businesses for estate tax purposes. The Court explained that, for purposes of federal...more
Connelly v. Internal Revenue Service is a landmark SCOTUS decision that will impact business owners, partners, shareholders, members, and professional practitioners from a business perspective, succession planning, as well as...more
It is typical to have provisions in the governing documents for your company which contemplate the death and buyout of the owners. Most often, those buyout obligations are funded by the purchase of a life insurance policy on...more
Keeping it in the family just got more complicated. Our Tax Group studies a Supreme Court decision that left a family with an unexpected estate tax liability related to a share redemption agreement....more
On June 6, 2024, the U.S. Supreme Court issued a pivotal decision in Connelly v. United States, affecting how life insurance proceeds are treated in buy-sell agreements for closely held corporations. The ruling states that...more
On June 6, 2024 the Supreme Court unanimously ruled that life insurance proceeds should be included in the fair market valuation of a corporation for federal estate tax purposes. In Connelly v. United States, the Supreme...more
In the recent case, Connelly v. United States, 602 U.S. (2024) (slip op.) the U.S. Supreme Court unanimously ruled that life insurance proceeds received by a closely held corporation which is used to fund the redemption of a...more
In early June, the Supreme Court issued an opinion that clarifies how company-owned life insurance impacts the value of the company for estate tax purposes. As a business owner, you may need to re-evaluate the use of those...more