Top Tax & Estate Planning Strategies Spring 2009
Jan 28, 2015
Top Tax & Estate Planning Strategies
Spring 2009
Gift assets to a trust for the benefit of family members, and control accessto principal, further ensuring sustainability of wealth.
FAMILY TRUSTS
Family Trusts
Grandparent
Trust
Spouse
Children
Grandchildren
TrusteeDistributesIncome/Principal
Common Trust Distribution Provisions
“Discretionary” Trust Income [and Principal, if desired] subject to an
“ascertainable standard” (for health, support, maintenanceand education only)
“Total Return” Trust A percentage of trust assets annually, paid out of income
and capital gains
“Incentive” Trust Distributions depend on beneficiary achievements Often “matching” distributions based upon child’ salary or
other meritorious achievements
“Dynasty” Trust A trust can be structured to “skip” generations and avoid
estate inclusion in the next generation Child’s control over principal must be limited
Transfer future appreciation on assets over a short term of years, without losingaccess to the current value of the underlying asset transferred, and withoutpaying gift tax.
GRANTOR RETAINED ANNUITY TRUST
Grantor Retained Annuity TrustTransfer Appreciation. Retain Principal. Reduce Gift & Estate Tax.
SeniorFamily
Member
JuniorFamily
Member
Trust
AppreciatedProperty
AnnuityFor Term of
Years RemainderInterestAdvantages:
1. Transaction is ignored for income tax purposes
2. Any appreciation in excess of IRS interest rate iseffectively transferred without gift tax
3. Taxable gift is limited to the present value of theremainder – annuity can be set high enough to“zero-out” the taxable gift and get back principalentirely
Grantor Retained Annuity Trust
What is a GRAT? A GRAT is an irrevocable trust
Grantor transfers appreciating property to the trust
Grantor receives an annuity amount for a short term of years(usually 2-5 years)
Grantor continues to pay income taxes on any income or gainsearned on the property, and annuity is disregarded
When the trust term expires, the remainder interest passes to theGrantor’s heirs, outright or in further trust
A taxable gift is computed when the property is transferred to thetrust, based only upon the value of the remainder interest
If properly structured, GRAT performance may beenhanced with valuation discount planning
Grantor Retained Annuity Trust
Advantages The annuity amount may be structured to
result in no taxable gift to the heirs
Future appreciation during the trust term inexcess of an IRS interest rate (2.4% in May2009) is transferred to heirs free of any gifttax Grantor must outlive GRAT term
Income tax paid on the trust property isessentially a tax free gift to heirs
If IRS challenges the asset valuation, theannuity self-adjusts, resulting in nounexpected taxable gift
GRAT is sanctioned under the InternalRevenue Code
Example #1
Situation:Parentwants to“freeze” thevalue of histaxableestate to thecurrentvalue,because heexpectscertainassets toappreciaterapidly
Solution:
Parent creates a $1,000,000 GRATwith a three-year term
Parent receives an annual annuitypayment for three years of $349,455
Parent has made no taxable gift
If the assets appreciate at 8% peryear for the three year term, the childwill inherit a tax-free gift of $125,242
Example #2
Situation:
Parent ownsa businessthat he wantsto movedown to hischildrenwithoutpaying gifttax. Hewould like aretirementcash flowfrom thebusiness.
Parent transfers $5,000,000 business to a 10year GRAT
Parent retains an annuity of $260,000, satisfiedfrom company distributions for 10 years
Taxable gift of $962,650 (assuming valuationdiscount of 35%) is sheltered by his lifetimetax-free gift allowance of $1million
At the end of 10 years, Parent is still alive andthe business is transferred outright to childrenwith no gift tax At that time, at 10% growth & income, it is
worth $8.8 million
Children can run and/or control the companyduring the GRAT term, if desired
The Fine Details of Strategy
Get the MostOut of YourGRAT
We can help with all the details to ensureyour GRAT is protected and performs: Trust agreement is flexible, to deal with
uncertain asset performance, a prematuredeath, and potential transfers Analysis of optimal GRAT term & annuity
amount Rollover and asset substitution options Marital deduction planning
Accurate gift and income tax reporting GST exemption allocations are frequent, costly
errors
Accurate and timely annuity payments Proper computations of asset ownership
between Grantor and Trust
Transfer future appreciation on assets, without losing access to currentvalue of the underlying asset transferred, and without paying gift tax.
Inter-Family Loans
Inter-Family Loan (Alt. #1)Transfer Appreciation. Retain Principal. Reduce Gift & Estate Tax.
SeniorFamily
Member
JuniorFamily
Member
Property
InstallmentNote
Inter-Family Loan (Alt. #2)Transfer Appreciation. Retain Principal. Reduce Gift & Estate Tax.
SeniorFamily
Member
JuniorFamily
Members
GrantorTrust
AppreciatedProperty
InstallmentNote
Balance ofTrust Assets
Planning Point:This Structure Avoids theRecognition of anyTaxable Gain on the Transaction
Inter-Family Loan (or Sale)
What is an Inter-Family Loan?
A parent loans cash, or sells assets to child, or to atrust for the benefit of child
Parent receives an installment note (alternatively, ademand note) for a term of years (usually a term lessthan parent’s life expectancy)
During the note term, any appreciation above theinterest rate on the note is transferred free of gift tax
If the note amount equals the fair market value of theassets loaned (or sold) no taxable gift results
If properly structured, loan performance may beenhanced with valuation discount planning
Inter-Family Loans
Advantages Get assets to children currently without gifttax
Future appreciation during the note term inexcess of an IRS interest rate (approx. 2%in 2009) is transferred to heirs free of anygift tax
If loan is between Grantor and his GrantorTrust
Entire transaction is disregarded for tax purposes
Income tax paid on the trust property isessentially a tax free gift to heirs
The transaction can be structured as ageneration-skipping planning vehicle
Example #1 Balloon Note
Parentwants to“freeze” thevalue of histaxableestate to thecurrentvalue, andwants tohelp kidsfund animportantpurchase,perhaps andbusiness
Solution: Parent sells $1,000,000 asset to child
(or a trust for the benefit of child)
Parent takes back a 9-year balloonnote for $1,000,000 with a 2% interestrate
Parent has made no taxable gift
If the assets appreciate at 8% peryear for the 9 year term, the child willinherit a tax-free gift of $749,000(before any income tax effect).
Example #2 Self-canceling Note
Parentneeds to doestateplanning tominimizeestate tax.Parent alsowants togive herchildren acashgeneratingasset.
Solution: Parent is 80 years old. She sells
$1,000,000 asset to a “grantor” trust forthe benefit of child.
Parent takes back an 8 year note with a2.4% interest rate
Note is self-canceling, if Parent dieswithin 8 years
Parent receives $185,400 a year forthree years, then dies and note isextinguished
$443,800 is transferred to heirs atParent’s death without gift or estate tax
The Fine Details of Strategy
Get the Mostout of YourLoanArrangement
We can help with all the details to ensure yourtransaction is protected and performs:
Loan documentation must be flexible andcomplete
Prepayment terms, adequate interest,renegotiations, transferability, selfcanceling features, downside valuationprotection
Timely payments
Capture upside appreciation
Gift and income tax reporting must bealigned
Creative capitalization options for a trustpurchaser
Transfer your second home to your children in the future at a significantlyreduced current gift tax cost, and retain the right to use the home indefinitely
Qualified Personal Residence Trust
Qualified Personal Residence TrustTransfer Vacation Home. Right to Use. Reduce Gift &Estate Tax.
SeniorFamily
Member
JuniorFamily
Member
Trust
VacationHome
PersonalUse
for term ofyears
RemainingAssets
What is a Qualified PersonalResidence Trust?
Grantor transfers home to a Trust
Grantor retains the right to use the home for a fixed period ofyears
At the end of the trust term, the house passes:
To a continuing trust for the benefit of children, or for thebenefit of spouse and children, or to children outright
A taxable gift occurs when home is transferred to the trust
The taxable gift is a reduced amount, equal only to thevalue of the trust remainder (after the fixed term)
If Grantor wants to continue to use the home after the fixedterm:
Grantor can rent the house back from children, or
Grantor can access the home through his survivingspouse’s income interest in a continuing trust, if any
Qualified Personal ResidenceTrust
Advantages Reduced upfront gift tax cost and the home is
removed from your estate Grantor must outlive QPRT term
Any future appreciation on the home is a tax-free giftto heirs Grantor must outlive QPRT term
Continued use of home Grantor may have to rent, after QPRT term ends
If home is sold and not replaced, QPRT converts to aGRAT
Nothing changes for income tax purposes, duringthe term The QPRT can sell the home and you can still use
your income tax exemption
You still deduct all the expenses during the QPRT term
Example
Grantor, age 60 transfers $1,000,000 family“heirloom” vacation home to a trust
Grantor continues to use the home for a period of15 years
At the end of 15 years, the home is transferred toa continuing trust for the benefit of spouse andchildren
Grantor can continue to use the home rent-freewhile is spouse is living, and thereafter must payFMV rent
Grantor’s taxable gift in year one is only $495,150 The home transferred to children free of gift tax in
year 15 is worth $2,078,000 at 5% appreciation
Example: Qualified PersonalResidence Trust with Continuing Trust
SeniorFamily
Member Trust
Vacation Home
PersonalUse
for Term ofYears
RemainingAssets
TrustSpouse
PersonalUse
for Life
JuniorFamily
Member
Vacation Home
Step 1
Step 2
Step 3
Step 4
The Fine Details of Strategy
Get the MostOut of YourQPRT
We can help with all the details to ensureyour QPRT is protected and performs Proper gift tax return reporting Gift-splitting elections and GST exemption
allocations are frequent, costly errors
Flexible document to address potential “real-life” situations in terms of what eventually willhappen to the home
Proper planning for real estate tax impact
Advanced structuring options, includingfractional share transfers, home exchanges,and reverse QPRT arrangements, andcontinuing spousal trusts
Reduce income and estate tax on an appreciated asset. Retain familyaccess to cash flow from the asset. Benefit charity in the future.
Charitable Remainder Trust
Charitable Remainder TrustSell Appreciated Asset. Reduce Income & Estate Tax. Benefit Family & Charity.
SeniorFamily
Members Trust
AppreciatedProperty
Annuity orUnitrust
Interest forLife or Term
of Years Remaining Assets
CharitableOrganization
What is a Charitable Remainder Trust?
Grantor transfers an appreciated asset to atrust
Grantor retains an income interest for life(lives)or a term of years (20 year max), or shorter of
Income interest is based upon a fixed percentage,trust income, or both
The fixed percentage is either an annuity (% of initialFMV) interest, or a unitrust (% of annual FMV) interest
At the end of the income interest the trustassets are distributed to an outside charity, ora family foundation
What is a Charitable Remainder Trust?
Different Types of CRTs: Unitrust (CRUT): Fixed percentage of annual FMV Annuity Trust (CRAT): Fixed percentage of initial FMV Net Income CRUT (NICRUT): lesser of trust income or
fixed percentage Net Income with Make-up CRUT (NIMCRUT): lesser of net
income or fixed percentage, with a make-up distribution inyears when net income exceeds % of FMV
FLIP CRUT: Lesser of income or % of FMV until aspecified event, then flips to a standard CRUT
Income interest must be 5%-50% of trust value peryear
Actuarial value of charitable remainder must be atleast 10%
Charitable Remainder Trust
Advantages An appreciated asset may be sold inside a CRT
without current income tax Good business succession strategy when coupled
with a corporate redemption
Good diversification strategy for concentrated stockposition
Income and gift (and/or estate) tax charitablededuction for the future value of charity’s interest,if properly structured
Retirement income tool, similar to an IRA Grantor can only access income interest
CRT is a tax-deferred vehicle, similar to an IRA Distributions to Grantor are taxable
Example #1 Sale of AppreciatedAsset
Situation:
Grantorneeds to sellsomeundiversifiedholdings toprotect herretirement.The incometax on thegain wouldbe significant.Grantor alsoneeds estatetax planning.
Solution: 65 year-old Grantor creates a CRT and
transfers $1,000,000 of appreciated assets
CRT sells the assets and realizes a$750,000 gain, but recognizes no gain fortax purposes
Grantor retains the right to 7% of the annualfair market value of the trust assets, totaling$1,290,000 (before taxes) for life (at an 8%rate)
Charitable deduction in year one is $357,050and charity receives $1,180,000 in year 18,at Grantor’s death
Grantor’s estate receives an estate taxdeduction for CRT assets included in estate
Example #2 Succession Planning
Situation:
Grantorwants to sellappreciatedbusiness tochildren. Hedoesn’t wantto pay asignificantincome tax.He wantsretirementcash flow.
Solution:
65 year-old Grantor creates a CRT andtransfers $1,000,000 of XYZ stock
CRT stock is later redeemed by XYZ
Grantor retains the right to a % of theannual fair market value of the trustassets for life
Children can operate the business, andnow own 100% of it.
Business can purchase life insurance onParent to replace redemption proceeds,if desired
Charitable Remainder Trust #2Charitable Bail-Out of Business
SeniorFamily
Members CRT
XYZ Stock
Annuity orUnitrust
Interest forLife or Term
of Years Remaining Assets
CharitableOrganization
XYZ
Cash toRedeemStock in
XYZ
XYZ Stock
The Fine Details of Strategy
Get the MostOur of YourCRT
Detailed analysis of income interest options:
CRUT, CRAT, NIMCRUT, NICRUT, FLIPCRUT –the options are dizzying
“Spigot” planning with an LLC investment toenhance strategy performance through moreincome tax deferral
Business succession planning with CRT and asubsequent corporate redemption
“Unwinding” options and analysis
Flexible document so that:
a private foundation is a remainder charity option
a charity can be switched
an income interest can be revoked
a hard-to-value or special asset is suitable
Transfer an income interest to charity for a term of years . When charity’s termends, trust assets are distributed to family. Reduce or avoid significant incomeand estate tax.
Charitable Lead Trust
Charitable Lead TrustReduce Significant Income & Estate Tax. Benefit Family & Charity.
SeniorFamily
Members Trust
AppreciatedProperty
IncomeInterest
for Term ofYears
RemainingAssets
CharitableOrganization
JuniorFamily
Members
What is a Charitable Lead Trust?
Grantor (or Grantor’s estate) transfers assets to atrust for the benefit of charity and his family
Charity receives a specified amount annually for aterm of years The amount can take the form of an annuity (fixed %
of initial FMV), or a unitrust (fixed % of annual FMV)
When the term ends, assets are transferred toheirs, or back to Grantor
May be structured to be suitable for use with aprivate foundation
May be structured to be suitable for a contributionof a closely-held business
Charitable Lead Trust
Advantages A CLT can produce significant estate & gift taxsavings if heirs receive the trust remainder
Taxable gift or estate is reduced by the value ofcharities income interest
CLT postpones assets to heirs, which may bedesirable if heirs are young
Lifetime CLT may be structured as a “grantor trust”,in which case Grantor receives an income & gift taxdeduction (but also pays tax on the CLT income)
Testamentary CLT can be based on a formuladesigned to effectively eliminate estate tax
If properly structured, can be a tremendous way touse generation-skipping tax exemption
Example #1 No estate tax plan
Grandfatherwants to usehisgeneration-skippingexemption of$2 million athis deathand alsowants tofund hisfamilyfoundationto avoid anyestate taxexposure
Grandfather dies and his estate transfers$4 million to a ten year, 7% CLUT
$2 million of his Generation-skipping taxexemption is used
$2 million charitable deduction is created
The CLT assets grow at 8% per year
His foundation receives a 7% unitrustpayment per year for ten years, totaling$2.9 million
In year eleven, his grandchildren inherit$4.4 million without further estate tax
Example #1Testamentary Charitable Lead Unitrust for Generation-Skipping
SeniorFamily
Member’s
EstateCLUT
AppreciatedProperty
See Note 1
UnitrustInterest
for Term ofYears
RemainingAssets
CharitableOrganization
Grandchildren
Note 1: A formula may be used topeg the GST exemption remaining
Example #2 Testamentary Charitable LeadAnnuity Trust For a Family Business
Situation:
Parent hassignificantestate taxexposure.He likes theidea offorming afamilyfoundation ,but wantshis kids tohave thefamilybusiness.
Solution
Parent revises his estate planning documents to set-up aTestamentary Charitable Lead Annuity Trust, and gives hischildren the option to buy the business from his Estate inexchange for a Note
When Parent dies, children may own and operate the businessimmediately (once probate court approves of it)
The children make interest payments on the Note (with cash fromthe business operations)
This cash is used to fund the Annuity to the family Foundation
When the CLAT terminates, the Note may be effectivelyextinguished because the children are on both sides of the Note
Estate tax may be effectively eliminated, and some futureappreciation during the TCLAT term may be an additional tax-freegift
Example #2 Testamentary Charitable LeadAnnuity Trust for a Family Business
SeniorFamily
Member’s
EstateCLAT
InstallmentNote
IncomeInterest
RemainingAssets
CharitableOrganization
JuniorFamily
Members
Business
InstallmentNote
Step 1: probatecourt approvaland sellbusiness tochildren
Step 2: fund CLATwith Note
Step 3: CLAT satisfies incomeInterest with Note payments
Step 4: When termends, Note is effectivelyextinguished, becausechildren inherit theCLAT remainder
The Result: estate tax elimination, and children immediately own the business
The Fine Details of Strategy
Get the MostOut of YourCharitableLead Trust
We can help you structure your CLT toensure that it is protected and performs Proper structure to accommodate the
funding of a family business or investmentcompany
Proper structure to accommodate the use offamily foundations
Creative financing structures to get familyaccess to CLT assets during the term
Flexible funding options, including fundingformulas and powers of appointment
Zero estate tax options and projections
Reduce estate tax, retain control, simplify asset management acrossmultiple family members, protect assets from creditors.
Family Limited Liability Company
Family Limited Liability Co.
SeniorFamily
Members
JuniorFamily
Members
LLC
InvestmentAssets
Contributed
Voting &NonvotingInterestsReceived
NonvotingInterests
Gifted or SoldOver Time Typical Structure on
Day One, is 98%nonvoting, 2% voting
What is a Family Limited Liability Co.?
Family members contribute investment assets to an LLC Family members take back a membership interest in the
LLC, based upon a their share of the total value ofassets contributed
Membership interests can be voting and nonvoting Typical structure is 98% nonvoting, 2% voting to
concentrate control among senior family members
LLC is operated by its Manager, a senior family member Family members must abide by LLC operating
documents, which lays-out access to distributions,transfers of ownership limitations, and liquidationproceeds
Distributions of income or principal are generally to bemade on a prorata basis
Family Limited Liability Company
Advantages Asset Management Benefits to Pooling Resources:
Access to alternative investments (especially fortrusts or individuals who don’t meet theaccredited investor definition)
Opportunity for better fee arrangements
Centralize family asset management with themost capable family members
Some investments, like private equity aren’ttransferable, so they can be “wrapped” in a familyLLC beforehand
Creditor Protection Benefits
Operating agreement restricts outsider or ex-spousal access to underlying assets
Family Limited Liability Co.
Advantages,continued
Family Acrimony
Arbitration, versus litigation mandates
Control Benefits
Nonvoting junior family members have littlecontrol over LLC operations, and discretionaryaccess to LLC assets
Simplify gift administration of real estate or otherassets that aren’t easily divisible
Avoid out of state probate on real estate
Valuation discounts on gifts or bequests may bepossible if properly structured
IRS could challenge discount amount
Example
Parentsneed estatetax planning,and is willingto transferappreciatingreal estatepropertiesandsecurities tochildren overtime, butaren’t readyto give upcontrol .
Parents contributes real estate LLCs andportfolio of securities to a family LLC
Parents receive voting and nonvoting interestsin the family LLC
Over time, parents gift family LLC nonvotinginterests to children
Parents manage the family LLC
Valuation expert determines that a 35%valuation discount is applicable for lack ofcontrol and marketability
$1,000,000 of ownership may be taxable asonly a $650,000 gift . This gift can be offset by the $13,000 per person
annual exclusion over a period of several years
Fine Details of Strategy
Get the MostOut of YourFamily LLC
Does Your Family LLC have abusiness purpose?
We can help you structure your FamilyLLC to that it is protected and performs
Careful monitoring of case law & legislation
Valuation discount historical data
Tracking of “bad fact” scenarios
Careful administration of LLC
Documentation of gifts, business meetings,capital accounts, prorata distributions
Careful drafting of LLC to optimize controlaspects and valuation discount potential
Avoid estate taxation of life insurance proceeds. Replace wealth going tocharity. Use proceeds to fund estate tax, business buy-outs, or spousalsupport.
Life Insurance Planning
Life Insurance Trust – During LifeAvoid Estate Tax on Proceeds. Benefit Spouse & Family. Provide Liquidity.
InsurancePolicy
Trust
Insured
Cash GiftforPremiums
InsurancePremiums
Life Insurance Trust – After DeathAvoid Estate Tax on Proceeds. Benefit Spouse & Family. Provide Liquidity.
InsurancePolicy
Trust
SpouseChildre
n
InsuranceProceeds
Income Principal
What is a Life Insurance Trust?
Grantor transfers cash to a trust
Trust is authorized to purchase insurance on thelife of the Grantor, within the terms of the trustagreement
Trust purchases life insurance on Grantor’s life
Grantor funds the trust every year with sufficientcash to pay the required insurance premiums
At Grantor’s death, trust collects the proceeds,and may use the proceeds to benefit survivingspouse and heirs, make loans to grantor’s estate,or buy-out a business partner
Life Insurance Trust
Advantages If properly structured, life insurance proceeds
are not included in Grantor’s estate Plan to avoid the ‘three year rule”
Leverage of insurance vehicle can passtremendous wealth in the event of apremature death
Surviving family members can access trustincome and principal
Insurance premiums can be covered withannual exclusions to avoid gift tax
Liquidity source to pay debts, death taxes,and redemptions
Creditor protection for trust assets
Example
Situation:
Parent wantsto buyinsurance toprotect hisspouse andprovideliquidity uponhis death toredeem out abusinesspartner. Healready has ataxableestate, andwants toavoid furtherexposure.
Solution Grantor gets pricing on a $1,000,000 insurance
policy
Grantor funds an insurance trust with sufficient cashto purchase the policy
Trust applies to buy insurance on Grantor
Trust pays the premiums directly to the insurancecompany
Grantor dies, and $1,000,000 proceeds arecollected by the trust, saving $450,000 in estate tax
Trust uses cash to buy-out business partner
Trust supports spouse with income from thebusiness
Fine Details of Insurance Planning
Get the MostOut of YourInsuranceTrust
We can help you plan to ensure your insurancetrust is protected and performs Creative structuring to avoid three-year rule for
existing policies
Creative financing structures for large premiums
Insurance leverage using qualified plan assets
Document drafting that ensures no estate taxinclusion
Trust administration to avoid incidents ofownership in the policy (causing estate inclusion)
Advanced planning to couple with charitablevehicles, family LLCs, buy-sells, and dynastytrusts
Diversify and avoid immediate income taxation
Concentrations in a Single Stock Position
Stock Diversification Strategies
Borrow Against Stock Position Up to 50% of the value, typically
Invest loan proceeds in a diversified portfolio
Still retain upside (and downside) on stock position
Put Options Downside protection in the event of a decline
Purchase put with cash premiums
If stock declines, you may: Sell the stock at a put option price which is higher than
current market price, or
Sell the option at a gain
Stock Diversification Strategies
Variable Prepaid Forward
Effective collar around the stock, with fulldownside protection and certain upsideparticipation
Receive substantial upfront cash advance relatedto a future stock sale agreement
Stock is pledged as collateral
Cash may be invested in a diversified portfolio
Transaction stays open 3-5 years, and capitalgains tax may be deferred during that time frame
Stock Diversification Strategies
Zero-Cost Collar Investor sells a call option, and purchases a put
option, so net cash outflow
Investor receives some downside protection, andsome upside participation
At maturity If stock is below the call option exercise price you pay
cash to brokerage firm (or deliver stock) for thedifference
If price is below put option exercise price, brokeragefirm will make a cash payment for the difference
Stock Diversification Strategies
Exchange Fund Investor contributes concentrated stock position
to an investment partnership
Other investors contribute stock positions, andthe result is a diversified portfolio
Limited partnership may invest in other assetclasses, like real estate to enhance diversification
After 7 years, the limited partnership terminates,and investors receive their share of the diversifiedportfolio of at least 10 stocks with incurring capitalgains tax
Stock Diversification Strategies
Transfer stock to a charitable trust or publiccharity Defer (or avoid) income taxation on stock
proceeds over your life
Receive income tax deduction for value expectedto go to charity
Avoid estate tax on stock
Receive an income stream for life, to support yourretirement: Charitable Remainder Trust,
Pooled Income Fund, or
Charitable Gift Annuity.
Disclosures
This presentation is for informational purposes only and is notintended to, and does not constitute tax advice.
Any U.S. federal tax advice contained in this document is notintended or written to be used, and cannot be used, for thepurpose of (i) avoiding penalties under the Internal RevenueCode, or (ii) promoting, marketing, or recommending toanother party any transaction or matter that is contained inthis document.
AVANT is a brand that refers to AVANT Financial, LLC andAVANT Advisors, PLLC. AVANT Financial, LLC is not a lawfirm or investment advisor and does not provide legal, tax orinvestment advice. AVANT Financial, LLC is an affiliate ofAVANT Advisors, PLLC, a Michigan law firm.
Please consult your personal legal and tax professionalsbefore proceeding with any financial, tax or estate planningstrategy.