Business Succession Planning, Including Life Insurance as a Planning Tool Webinar

To provide CPAs, accountants, and tax professionals with the technical expertise, knowledge, and strategic frameworks needed to design effective business succession plans, optimize buy-sell agreements, and properly use life insurance as an estate planning tool.

• Strategies for sales of business interests to family members
• Goals of any business sale in a family setting
• Payment options
  – Cash sale
  – Traditional installment sale
  – Self-cancelling installment note
  – Private annuity
  – Combination
• Income in respect of a decedent (IRD Section 691)
• Comparisons of:
  – Ordinary income tax consequences
  – Capital gains realized during lifetime of seller
  – Federal estate tax inclusion
  – Post-death capital gain
  – Payment strategies
  – Traditional installment sale vs. SCIN
  – SCIN vs. Private Annuity
• Selected issues in buy-sell agreements
  – Post-death sale issues
  – Section 754 elections
  – S Corporation redemptions of stock, when funded by life insurance
  – Interim closes
• Life Insurance: Estate and income tax issues
• Life insurance as an estate planning tool
  – What is an ILIT?
  – Benefits of ILIT
  – Gift tax implications
  – ILIT with a survivorship policy
• Aftermath of the Connelly case
  – Life insurance payable to corporations
  – Other considerations
  – Shareholders’ agreements post-Connelly

Michael F. Rogers, Esquire, Head of Tax and Estates Department, Salvo Rogers

Michael F. Rogers, Esquire, is the head of the Tax and Estates Department of Salvo Rogers. He has over 20 years of experience advising clients on a wide variety of tax, estate and business matters. He was a member of the Tax Department of Arthur Young & Company (now Ernst & Young, LLP) for several years, and was a Vice President and Tax Manager with Butcher & Company in Philadelphia. He has been a shareholder of several Philadelphia area law firms, specializing in Tax and Estate Planning. He is a frequent lecturer for continuing education programs for attorneys, accountants and financial advisors, and has had many articles published.

To provide CPAs, accountants, and tax professionals with the technical expertise, knowledge, and strategic frameworks needed to design effective business succession plans, optimize buy-sell agreements, and properly use life insurance as an estate planning tool.

DETAILED LEARNING OBJECTIVES

• Explain how a sale of a business interest to a family member may freeze or reduce the value remaining in the seller’s estate

• Identify the income tax consequences of a business transfer using a private annuity under the post-October 2006 rules

• Recognize installment-sale gain not reported before death as income in respect of a decedent

• Determine whether a buy/sell agreement expressly covers related or brother/sister entities

• Explain how a Section 754 election may adjust a transferee’s share of the basis in a partnership’s underlying assets

• Explain how an S corporation’s interim closing-of-the-books election can allocate tax exempt insurance proceeds and affect shareholder basis

• Apply Revenue Ruling 93-12 when valuing a noncontrolling business interest transferred within a family

• Determine how an outstanding owner loan should affect the purchase price in a substantially cash-based business buyout

• Identify policy rights—such as the right to change beneficiaries—that constitute incidents of ownership under Section 2042

• Explain the general federal income-tax exclusion for life insurance death benefits under Section 101(a)(1)

• Describe how an ILIT can keep life insurance proceeds outside the insured’s taxable estate

• Explain how Connelly v. United States affects the estate tax valuation of a corporation receiving insurance proceeds for a stock redemption

• Evaluate the administrative challenges of using traditional cross-purchase agreements for businesses with numerous shareholders

• Strategies for sales of business interests to family members
• Goals of any business sale in a family setting
• Payment options
  – Cash sale
  – Traditional installment sale
  – Self-cancelling installment note
  – Private annuity
  – Combination
• Income in respect of a decedent (IRD Section 691)
• Comparisons of:
  – Ordinary income tax consequences
  – Capital gains realized during lifetime of seller
  – Federal estate tax inclusion
  – Post-death capital gain
  – Payment strategies
  – Traditional installment sale vs. SCIN
  – SCIN vs. Private Annuity
• Selected issues in buy-sell agreements
  – Post-death sale issues
  – Section 754 elections
  – S Corporation redemptions of stock, when funded by life insurance
  – Interim closes
• Life Insurance: Estate and income tax issues
• Life insurance as an estate planning tool
  – What is an ILIT?
  – Benefits of ILIT
  – Gift tax implications
  – ILIT with a survivorship policy
• Aftermath of the Connelly case
  – Life insurance payable to corporations
  – Other considerations
  – Shareholders’ agreements post-Connelly

Michael F. Rogers, Esquire, Head of Tax and Estates Department, Salvo Rogers

Michael F. Rogers, Esquire, is the head of the Tax and Estates Department of Salvo Rogers. He has over 20 years of experience advising clients on a wide variety of tax, estate and business matters. He was a member of the Tax Department of Arthur Young & Company (now Ernst & Young, LLP) for several years, and was a Vice President and Tax Manager with Butcher & Company in Philadelphia. He has been a shareholder of several Philadelphia area law firms, specializing in Tax and Estate Planning. He is a frequent lecturer for continuing education programs for attorneys, accountants and financial advisors, and has had many articles published.