9:45–10:15 a.m. | REGISTRATION | |
10:15–10:20 a.m. | Welcome and Introduction | Parker Taylor |
10:20–11:10 a.m. | QSBS: Small Business Stock, Very Big Exclusion In this session, the speakers will discuss the tax benefits and planning opportunities available under International Revenue Code (IRC) §1202, including how recent legislative changes have expanded the exclusion and what practitioners need to watch for when advising clients on QSBS matters. Topics include: Overview of QSBS gain exclusion rules, eligibility requirements, historical exclusion percentages/caps and the impact of the One Big Beautiful Bill Act. The $10 million/$15 million cap versus the 10x basis limitation, and how these apply on a per-issuer basis. Estate planning strategies, pitfalls and case studies involving QSBS, such as “stacking” and “packing” to multiply the exclusion, gifts to a spouse, and the use of charitable remainder trusts or holding companies.
| Abby Feinman Jonathan Byer Christina Romero |
11:10 a.m.–12:00 p.m. | Challenging and Defending Diminishing Capacity, and Dealing with Failure To Plan This session will address the interrelation of claims of undue influence with claims of diminishing capacity, and lessons to be learned from the failure to plan. Fraud, mistake, duress and undue influence have long been grounds to contest the execution of wills and trusts, separate and apart from the ground of lack of capacity. As life expectancies continue to rise, testators and grantors make changes to their dispositive plans ever later in life. And as people make huge amounts of money, achieve fame and die tragically at young ages, their estates become subject to attack by reason of their failure to plan. This session will discuss (1) how to establish and how to defend against claims of fraud, mistake, duress and undue influence when the subject of the claim is suffering from diminishing capacity and (2) what the failure to plan teaches us and how to encourage creators of wealth to have plans in place at all times. Topics include: How much influence is permissible, and when does it become undue? Predatory late-in-life marriages and diminishing capacity to marry. When does undue influence become elder abuse, and what are the obligations to report such claims? What lessons emerge when creators of wealth fail to plan? What lifetime options address claims of undue influence? What post-mortem options address claims of undue influence?
| Joshua Rubenstein Bonnie Chmil |
12:00–1:30 p.m. | LUNCH | |
1:30–2:20 p.m. | Trust Me, It’s Complicated: Advanced Drafting Ideas for Wealthy Clients In this session, the speakers will discuss ways to draft estate planning documents to maximize effectiveness and minimize potential issues. Topics include: Best practices for sophisticated drafting. Flexibility in planning for unforeseen circumstances. How to avoid disputes with clear and concise drafting.
| Parker Taylor Marla Franzese |
2:20–3:10 p.m. | Trusts and Estates: What’s Changed, What Matters, and What’s Coming In this session, the speakers will discuss recent legislative updates and case law decisions in trusts and estates, and how each impacts the way we practice. Topics to be covered include: What’s Changed: Recent changes to the trusts and estates statutory and judicial landscapes, locally and nationally. What Matters: Modifications to estate planning strategies and drafting as a result of new developments. What’s Coming: Potential expansion of gift and estate tax impacts and fiduciary risk in light of recent developments and technological advancement.
| Ronni Davidowitz Rebecca Lomazow |
3:10–3:30 p.m. | BREAK | |
3:30–4:20 p.m. | Crossing Your T’s and Dotting Your I’s: Advanced T-CLAT Planning for Complex Business Interests In this session, the speakers will discuss specific charitable planning strategies to utilize at death to benefit charity, transfer assets to family members and minimize estate tax. Topics include: Charitable planning strategies to reduce estate tax. Problem solving for lack of liquidity. Illustration of a testamentary charitable lead trust (the frozen T-CLAT).
| Cynthia Altchek Emily Tuten |
4:20–5:10 p.m. | Offshore Trust Structures and Strategies in a Shifting Political Landscape In this session, the speakers will discuss how global volatility and shifting political landscapes are impacting our high-net-worth clients in their decisions to move to and from the United States, and specifically, considerations for clients exiting the United States. Topics include: Pull and push factors for moving to and from the United States in general. Challenges to entering the United States: Challenges to leaving the United States: US income, estate and gift tax issues for “covered expatriates.” Compliance and local tax issues abroad and practical considerations.
Planning objectives before entering or leaving the United States.
Trust planning before entering or leaving the United States | Kathryn von Matthiessen Ali Copell Andrew Toporoff |
5:10–5:15 p.m. | Closing Remarks | Parker Taylor |
5:15–6:30 p.m. | NETWORKING RECEPTION | |