Florida Banking March 2024

Five Lessons, Continued from page 17

Mark R. Parthemer, AEP, is Glenmede’s Florida regional director and chief wealth strategist. Glenmede is an independent investment, wealth management firm, and trust company, working with high-net-worth individuals, families, family offices, foundations, endowments, and institutional clients. This article is provided solely for informational purposes and is not intended to provide financial, investment, tax, legal, or other advice. It contains information and opinions which may change after the date of publication. The author takes sole responsibility for the views expressed herein, and these views do not necessarily reflect the views of the author’s employer or any other organization, group, or individual. Information obtained from third-party sources is assumed to be reliable and has not been verified. No outcome, including performance or tax consequences, is guaranteed, due to various risks and uncertainties. Readers should consult with their own financial, tax, legal, or other advisors to seek advice on their individual circumstances.

fully gift tax taxable. This is known as the Atkinson rationale1 (CCA 202152018 (Dec. 30, 2021)). Conclusion Pre-sale planning can be powerful in furthering clients toward achieving their financial, tax and estate planning goals. However, as we have seen, despite the rules in this area not materially changing in years, mistakes still occur. From them, we can learn about assigning income, substantiating charitable deductions, binding the IRS with a buy-sell agreement, valuing the company that owns life insurance to fund a redemption, and not being frugal when it comes to obtaining appraisals. Armed with this knowledge, we can see the legal context for the early and careful counsel. Perhaps an insight from Edward Gibbon may apply, “Vicissitudes of fortune, which spares neither man nor the proudest of his works, which buries empires and cities in a common grave.”2 In the meantime, if the IRS dragon is lurking outside the door, do not pretend it isn’t there.

1. In Atkinson v. Commissioner, 115 T.C. 26, 32 (2000), aff’d, 309 F.3d 1290 (11th Cir. 2002), the Court treated as non qualifying a charitable remainder annuity trust when no payments were actually made to the donor during the two-year period between the creation of the trust and the donor’s death. 2. Edward Gibbon, “The History of the Decline and Fall of the Roman Empire,” W. Strahan and T. Cadell, in the Strand, 1776.

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