High Net-Worth Estate Planning:
- Hoffman & Associates designed an integrated estate and succession plan for a high net-worth client. The value of the estate was $85 million. The plan design included use of dynasty non grantor trusts, dynasty defective grantor trusts, family limited liability companies and discounted gifting, self cancelling installment notes, irrevocable life insurance trusts, and grantor retained annuity trusts. The plan reduced estate tax exposure by an estimated $24 million initially, but additional estate tax savings are expected as family wealth accumulates in trusts outside of the estate tax system.
- Hoffman & Associates designed and implemented an estate plan over a period of a decade that has resulted in over $60 million worth of assets held in family dynasty trusts, protected from creditors and divorce and outside of estate tax exposure. The value of the estate initially consisted of a small business worth between $20 and $30 million, but has continued to grow substantially year over year. Included in the plan design were dynasty life insurance trusts, dynasty non-grantor trusts, dynasty defective grantor trusts, grantor retained annuity trusts, family limited partnerships and limited liability companies, discount planning and gifting, and self cancelling installment notes. Over three-fourths of family wealth now resides safely in family dynasty trusts, protected from creditors, divorce and outside of estate tax exposure.
- Through proper planning, creative thinking, and hard work, Hoffman & Associates was able to defend a key client’s estate from an additional $2.4 million in estate taxes assessed by the IRS after an audit.
- Hoffman & Associates successfully settled an estate tax case for $1.25 million saving our client over $8 million in taxes, penalties and interest.
Tax Planning and Tax Controversy:
- Through a collaborative effort between the client, his accountant, and the Hoffman & Associates team, we were able to reduce his income tax assessment from over $160,000 to a mere $436.
- Hoffman & Associates was successful in obtaining a $55,000 abatement for a client after he was assessed late filing and late payment fees by the IRS.
- Hoffman & Associates was successful in obtaining an abatement of penalties in the amount of $56,000 for late payment of taxes after our client’s CPA filed a request that had been denied by the IRS.
- Due to the depth of knowledge and expertise displayed by the Hoffman & Associates team, our client was successful in obtaining an abatement of $103,000 in IRS penalties assessed against the estate for filing a late tax return.
- Due to the extensive effort of the Hoffman & Associates team, an LLC was able to continue operations after the IRS accepted removal of a wrongful levy. The IRS had placed a $1.5 million lien against each individual of this LLC and if that lien had been satisfied, it would have been catastrophic for the operating business.
- The wide range of skills and knowledge possessed by the Hoffman & Associates tax controversy team helped our client successfully obtain an abatement of over $700,000 in self dealing transaction penalties under Internal Revenue Code Section 4941.
- Hoffman & Associates successfully obtained an involuntary exchange extension to find replacement property for one of our clients after the IRS had rejected the request for being 18 months past the end of the 3 year replacement period.