In this world of constant uncertainty, only one thing is clear, planners need a roadmap in order to be successful in crafting strategies to preserve and protect their clients’ wealth.
Planning for large estates: enhanced note sales to grantor trusts (“IDITs”) for UHNW client wealth transfers; consider “stepped” or deferred interest on promissory notes to facilitate a larger sale than current cash flow may permit; be wary of the Hart Scott Rodino Act requirements; differentiate collateral on note sale to possibly break IRS challenges of a retained interest on a note sale; defined value mechanisms might be enhanced and modified for new planning…