• videocam On-Demand Webinar
  • signal_cellular_alt Intermediate
  • card_travel Estate Planning
  • schedule 90 minutes

Reducing Estate Tax Liability in Corporate Recapitalization: Stock Freezes, Sec. 2701 Rules, Coupling With Gifts

$297.00

This course is $0 with these passes:

CLE
CPE
ALL
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About the Course

Introduction

This CLE/CPE webinar will provide estate planners, advisers, and tax counsel with a comprehensive exploration of reducing estate tax liability in corporate recapitalizations. The panel will discuss critical planning and structuring challenges and key considerations in freezing stock value versus holding the stock until death and receiving a step-up basis for income tax purposes.

Description

A stock freeze in a corporate recapitalization can be a valuable and flexible estate planning tool. In its most basic form, a properly structured recapitalization can freeze the value of the owner's stock, potentially reducing the owner's estate tax liability by removing future appreciation in the value of the stock from the estate. Estate planners and tax counsel must understand the complex tax rules to avoid potentially costly consequences and achieve significant income tax savings.

When structuring a stock freeze, the owner of a closely held corporation recapitalizes the corporation by creating two classes of stock (common stock and preferred stock). The owner then transfers part of their interest in the business by gifting or selling the common stock while retaining a portion of the company in the form of the preferred stock. This allows any future appreciation in the business to be attributed to common stock transferred out of the owner's estate with the value of the retained interest remaining constant or frozen.

However, advisers must carefully navigate the technical rules of IRC Section 2701 or the transfer may result in a deemed taxable gift. In addition, advisers must also consider the tax rules and implications of recapitalizing with two classes of common stock, coupling a recapitalization with gifts of stock, distribution rights, qualified payments, and other vital issues.

Listen as our experienced panel provides a thorough guide to the benefits, risks, and structuring techniques of corporate recapitalization and stock freezes in estate planning.

Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

  • CPE credit is not available on recordings.

  • BARBRI is a NASBA CPE sponsor and this 90-minute webinar is accredited for 1.5 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).


  • Live Online


    On Demand

Date + Time

  • event

    Tuesday, September 20, 2022

  • schedule

    1:00 p.m. ET./10:00 a.m. PT

  1. Advantages of the stock freeze over other techniques
  2. Understanding IRC 2701 provisions
  3. Valuation issues
  4. Structuring the freeze to maximize basis step-up
  5. Drafting and structuring transfers
  6. Sample language and illustrations

The panel will review these and other key issues:

  • Typical structures of corporate recapitalization
  • Freeze techniques and structures
  • Gift tax issues to avoid
  • How not to run afoul of the requirements in IRC 2701
  • State and local income tax considerations
  • Recent developments

Learning Objectives

After completing this course, you will be able to:

  • Identify tax issues in corporate recapitalization
  • Ascertain freeze techniques and structures to minimize adverse tax consequences
  • Recognize gift tax issues to avoid
  • Understand how not to run afoul of the requirements of IRC 2701
  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite: Three years+ business or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of estate, gift and trust taxation including various trusts types, the unified credit, and portability.

BARBRI, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

BARBRI CE webinars-powered by Barbri-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .