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Estate Tax Secret Liens; Charitable Gifts; Preferred Partnerships


Cost Free
Presentation Length 1.5 hours

Recorded DateDecember 4, 2023
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelAdvanced
Course Description

This course discusses liens from deferred estate tax on businesses, irrevocable grantor trusts and basis step-ups, and charitable gifts of business interests. Some business owners rely on estate tax deferral for their business interests. Most of them are unaware of automatic secret liens and how the IRS’s need to secure payment of estate tax may interfere with their businesses’ ability to retain and expand loans or fidelity bonds. The IRS recently updated its lien procedures. We will discuss these issues. 

Revenue Ruling 2023-2 confirmed that assets held in an irrevocable grantor trust do not get a basis step-up merely because the deemed owner died. This course will discuss how premature death can cause a sale to an irrevocable grantor trust to cost more than it saves and how a preferred partnership may be an attractive alternative. This course will also discuss a case that radically departed from precedent regarding when a donor will be taxed on a charity’s sale of a donated asset. The case also addressed what constitutes “delivery” of stock. The presenter will discuss planning in light of this case, as well as other issues relating to donating to a business interest.

Learning Objectives: 

  • Summarize the Code §6166 qualifications and benefits of deferral 

  • Determine how to plan for loss of Code §6166 deferrals when using a sale to an irrevocable grantor trust 

  • Outline the description of estate tax liens, their effects, and how to navigate 

  • Recognize the lack of basis step-up on the death of the grantor of irrevocable grantor trust 

  • State how basis step-up is essential for real estate 

  • Define preferred partnership: structure, income, estate tax issues, and planning 

  • Identify the assignment of income rule 

  • Determine when a transfer of business interest is completed 

  • List charitable planning issues unique to business interests

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Thompson coburn llp

Steve has drafted trusts and a full range of estate planning documents for clients to help grow, preserve, and transmit their family wealth. He has also prepared organizational documents for limited liability companies, corporations, and partnerships to implement their owners' wishes regarding current and future control and transmission, including bringing in new owners and facilitating exit strategies. 

Steve enjoys helping clients structure their affairs to achieve their personal, business, and financial goals while reducing the drag that taxes imposed on them. His firm provides full service to businesses; however, he also acts as counsel on specialized matters while cooperating and facilitating the continued involvement of an existing legal, accounting, and financial services team. Steve maintains his CPA license but prefers to refer income tax returns to practicing CPAs.

Steve Gorin is the former president and an ongoing contributor to Covenant Place’s strategic initiatives. It is a senior affordable housing community with a groundbreaking model for integrated residents with the surrounding community and facilitating holistic services to enrich their lives. 

To know more about Steve Gorin, kindly click on the link below:

For various free resources Steve offers, see

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About Our Presenter

Thompson coburn llp

For approximately 90 years, Thompson Coburn LLP has provided the quality legal services and counsel our clients demand to achieve their most critical business goals. Whether helping with a tax, estate planning, real estate or employment issue, navigating a complex acquisition or defending a product or service in litigation, we have the knowledge and resources to meet any legal need.

With over 380 attorneys, we have experience in more than 50 areas of the law. Supported by our firm's state-of-the-art technology, lawyers in our Chicago, Dallas, New York, Los Angeles, Southern Illinois, St. Louis and Washington, D.C. offices enjoy a nationwide practice.