Overview The freeze partnership technique (the "technique") has been used for decades to transfer wealth to the next generation while reducing estate, gift, generation-skipping and income taxes. Despite being explicitly authorized under Internal Revenue Code...
Recent legislative developments, including the One Big Beautiful Bill Act (OBBBA) and the resulting expansion of the federal lifetime gift and estate tax exemption, have created a significant planning window for high‑net‑worth individuals to deploy exemption, either...
Why charities reject debt-financed real estate gifts At first glance, leaving real estate to charity seems straightforward. In practice, highly appreciated property encumbered by mortgage debt is frequently declined. Public charities and private foundations are...
I. Introduction The Internal Revenue Code (the “Code”) and accompanying regulations provide no explicit guidance directly addressing disguised sales of partnership interests. While the IRS issued proposed regulations under Treas. Reg. § 1.707-7 in 2004...