The year 2020 has been mired with uncertainty and unprecedented strife for many.
As we reflect on the past six months and prepare for the next, now may be an opportune time to consider fine-tuning your business succession strategy. 提前计划会让你高枕无忧, knowing that your affairs are under control in these unsettled times.
让我们以合作关系为例. 没有适当的继任计划, 合伙人死亡或丧失行为能力, that partner’s interest may experience undesired distribution, 失去了价值, 被迫出售或商誉问题, 更别提高额的遗产税了. Estate planning offers some convenient solutions to better navigate such events.
Though a partner may draft his or her will to guide executors on how to manage their assets upon death, there are several steps a business owner can take during their lifetime to ensure their assets are managed in a 税-efficient manner.
One useful estate planning tool is the Intentionally Defective Grantor Trust, or IDGT. An IDGT is structured so that the grantor pays the income 税 on the trust’s income since the IDGT is considered owned by the grantor. The trust, however, is not included in the grantor’s estate. This may allow the trust to be 税ed at a lower rate during the grantor’s lifetime while avoiding both gift and estate 税.
举个例子, a partner may create an IDGT and sell a portion of their interest to the trust for a promissory note. 出售本身不属于应税交易, 但合伙人将继续为收入纳税. Payments on the promissory note made to the partner are from distributions in the sold partnership interest, but the IDGT shelters the partner’s interest from both gift and estate 税.
Another useful estate planning tool is the Grantor Retained Annuity Trust, or GRAT. This trust is irrevocable and allows a business owner to transfer their shares of a partnership to the trust while retaining the right to a fixed annuity for a certain number of years. The annuity can be also be paid with distributions from the partnership to the trust. 学期结束的时候, 哪些必须在伴侣的有生之年失效, the property remaining in the GRAT passes on to children or an intended beneficiary.
施耐德唐斯, our team of experienced 税 professionals are here to help you make 税-efficient decisions that best suit you, 你的家庭和你的事业. 请随意 bet9平台游戏 如对上述资料有任何查询.
来源:
合伙企业税务规划和实践-查尔斯R. leun，¶6565，故意有缺陷的授予人信托
合伙企业税务规划和实践-查尔斯R. Levun,¶9689,IRS Provides Helpful Guidance for Sales of Property to Intentionally Defective Grantor Trusts
金融 & 遗产规划, 西德尼凯斯, 咨询编辑:文章,¶33,121,Practical Succession Planning for the Family-Owned Business 1
©2008 S.V. 格拉西和J.H. Giarmarco
Reproduced from the J ournal of P ractical E state P lanning, a CCH Tax and Accounting Publication.
作者:塞巴斯蒂安·V. 小葛,. 朱利叶斯·H. Giarmarco *
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