Advanced Estate Planning Practice Update – Spring 2007
Why Attend?
Topics are selected with emphasis on identifying and solving problems that practitioners will confront in their practice. Any reporting on changes in the law or regulations analyzes what to do with or about the changes — what documents or planning are affected — and not merely describes them. The roundtable discussion stresses how to bring about desired results, examining alternatives that the featured practitioners are using or have rejected — and why — as well as when and why particular procedures or choices are appropriate. Those attending learn how to improve practice opportunities and skills and adopt new drafting approaches.
Updated in May, the list below is a work in progress. Other important topics may supplement or supersede these, depending upon further developments.
Inside the Beltway Washington Update on Pending Legislation
Treasury Department/Internal Revenue Service Priority Guidance Plan promulgations - if issued*
Rudkin Testamentary Trust v. Commissioner: petition for certiorari
Estate of Hester v. U.S.: postmortem facts in a §2053(a)(4) deduction valuation
Dallas v. Commissioner defined valuation formula clauses
Warner v. U.S.: equitable recoupment
Estate of Stewart v. Commissioner. §2036(a)(1) retained enjoyment
Caselaw developments under Uniform State Laws
In re Lawrence: contempt lifted for settlor of offshore asset protection trust
Rev. Rul. 2007-13: grantor trust rule avoidance of §101(a)(2) transfer for value rule
PLR 200647022: "care" as an ascertainable standard
PLRs on University Endowment Units and Unrelated Business Taxable Income
Estate of Roski: Bond Requirement for §6166 Installment Payment
Estate of Erickson v. Commissioner §2036(a)(1): FLP Discount Denied
Pfeufer v. Cyphers, State Inheritance Tax Apportionment
EC Term of Years Trust v. United States
*If Issued
GST Severance Final Regulations--if issued
§2036 v. §2039 inclusion guidance - if issued
Joint settlor trusts revenue ruling - if issued
§67(e) 2% haircut guidance - if issued
Plus Questions and Answers
What You Will Learn
Designed for practitioners whose experience is at an intermediate (or higher) level, this three-hour update offers an opportunity to explore the most current and important issues in estate planning and wealth transfer taxation. Similarly experienced accountants and fiduciaries also may find the program to be useful to their practices.
Registrants are encouraged to send questions for the faculty panel in advance of the program, so that these may be integrated into the discussion. Because of late-breaking developments, accompanying written materials supplement the discussions, rather than provide extensive outlines on every topic.
Planning Chairs
Jeffrey N. Pennell, Richard H. Clark Professor of Law, Emory University School of Law, Atlanta
Faculty
Ellen K. Harrison, Pillsbury Winthrop Shaw Pittman LLP, Washington, D.C.
Lawrence P. Katzenstein, Thompson Coburn LLP, St. Louis
Carlyn S. McCaffrey, Weil, Gotshal & Manges LLP, New York
Judith W. McCue, McDermott, Will and Emery LLP, Chicago
Program Schedule
(All times are EASTERN DAYLIGHT)
12:00 noon Introduction and Overview; In Re Lawrence; §2036 v. §2039; Priority Guidance Plan Promulgations; Rudkin; Inside the Beltway; Litigation Update - Mss. McCaffrey and Harrison, and Mr. Pennell
12:34 p.m. Kiddie Tax; Estate of Erickson; Stone; Rev Ruls. 2007-24; 2007-38; 2007-13 - Ms. Harrison and Messrs. Katzenstein and Pennell
1:07 p.m. Dallas; Roski; Warner; Stewart; PLR 2006647022; Notice 2007-50 - Messrs. Katzenstein and Pennell
1:25 p.m. Intermission
1:40 p.m. Questions and Answers; § 2053 Proposed Regs - Mss. McCaffrey and McCue, Messrs. Katzenstein and Pennell
2:04 p.m. Hester; Uniform State Laws: Lilly; Pfeufer; KSR International - Ms. McCue and Messrs. Katzenstein and Pennell
2:45 p.m. University Endowment Units and UBT; Goldman; Brownstone; Tax Strategy: Patent Developments; Questions and Answers - Mss. Harrison, McCue, and McCaffrey
3:15 p.m. Adjournment - Mr. Pennell
Total 60-minute hours of instruction: 3.0
Suggested Prerequisite: Substantial experience in legal practice in subject matter
Educational Objective: Maintenance of professional competence as a practitioner; provision of information on recent legal developments; development of proficiency in performance of intricate and complex legal tasks within a narrow area.
Level of Instruction: Intermediate or higher
Times
Eastern 12:00 noon
Central 11:00 a.m.
Mountain 10:00 a.m.
Pacific & Arizona 9:00 a.m.
Alaska 8:00 a.m.
Hawaii 6:00 a.m.
