Tax Policy Counseling

For high-net worth individuals, executives and families, tax planning is an important step in ensuring that assets are protected and transferred in a manner that is consistent with their personal and business objectives. The Private Wealth Services team at McGuireWoods works with clients to identify and implement effective wealth-preservation strategies — including the orderly and tax-efficient succession of privately held and family-owned businesses — that comply with the requirements of federal and state taxing bodies. We also provide tax controversy services, helping clients resolve tax disputes through rulings and technical advice in the national office of the Internal Revenue Service (IRS) as well as in administrative appeals throughout the country.

We regularly advise clients on planning and controversy matters involving estate, gift and generation-skipping transfer taxes, income taxation of trusts and estates, charitable contributions and related tax issues. We help clients obtain tax-exempt status for family charitable foundations and have obtained numerous private letter rulings from the IRS on a range of tax questions, including the split-up of private foundations, the restructuring of trusts, stock repurchases, estate tax deductions and the conversion of marital trusts to a unitrust, among other issues.

Our lawyers are some of the most experienced in the area of tax policy as it applies to individuals and families, and have served in leadership positions for The American College of Trust and Estate Counsel and the American Bar Association's Section of Taxation. Among our number are fellows of The American College of Tax Counsel and the American Bar Foundation, and members of the International Academy of Estate and Trust Law.

In addition to our tax policy counseling work on behalf of individual clients and families, we also advise major trade organizations on tax issues affecting banks and trust companies in the areas of fiduciary income tax and estate, gift and generation-skipping taxes. Since the 1970s, our lawyers have contributed to the formation of estate tax policy through legislation, and to the prevention of overly burdensome U.S. Treasury and IRS regulations and guidance through public and private participation in the comment process.

Experience

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    Major trade organization

    Advised major trade organizations on tax issues affecting banks and trust companies in the fiduciary income tax and estate, gift, and generation-skipping tax areas.

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    Provider of asset administration and trust and fiduciary services

    Contributed to the prevention of the issuance of overly burdensome Treasury or IRS guidance through public and private participation in the comment process.

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    High net worth individuals

    Obtained an IRS letter ruling allowing a conversion of a marital trust to a “unitrust” measuring the annual payout by a graduated scale of percentages of value, elaborating the standard in the regulations.

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    High net worth individuals

    Obtained an IRS letter ruling favorably addressing the overlap between the charitable and marital estate tax deductions in a sophisticated flexible estate plan.

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    High net worth individuals

    Obtained an IRS letter ruling elaborating the exception in the regulations from the special valuation rules applicable to stock repurchase agreements when less than half of the stock is owned by family members.

Team Leaders

Full Team
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