Jeffrey Zisselman, formerly of New York, NY, Now in Northern California
25 October 2006Jeff Zisselman is another client in financial services, estate planning and tax advisory. We just put up a place holder website for Jeff at www.MedalistandCompany.,com and are currently updating his other websites.
Jeffrey N. Zisselman also just prepared the following brochure that I am converting into HTML and posting on his websites. Here is a glimpse:
Front Side of Brochure
Core Estate Planning
The 5 Stage Approach
Stage I Core Estate Planning Documents
Revocable Living Trust
Pour-Over Will
Durable Power of Attorney
Living Will / Health Care Directive
Stage II Discount Estate
Family Limited Liability Company
Family Limited Partnership
Recapitalize S Corporations
Fractionalize
Stage III Move Assets & Provide Liquidity
Annual Exclusions
Use of Applicable Estate Tax and
Generation Skipping Exemption Transfer
Intentionally Defective Irrevocable Trust
Grantor Retained Annuity Trust
Qualified Personal Residence Trust
Irrevocable Life Insurance Trust
Stage IV Charitable Planning
Charitable Remainder Trust
Charitable Lead Annuity Trust
Private Foundations
Stage V Asset Protection
Qualified Retirement Plans
International Asset Protection Trust
Captive Insurance Companies
International Private Placement
Variable Life Insurance
Back Side of Brochure
Core Estate Planning
Definition of Terms
Stage I Core Estate Planning Documents
Revocable Living Trust (RLT)
Pour-Over Will
Durable Power of Attorney
Living Will / Health Care Directive
Stage II Discount Estate
Family Limited Liability Company (FLLC)
Family Limited Partnership (FLP)
The purpose is to consolidate management investment, and disposition of assets in a single business entity,and transfer economic interests in the assets to younger generations without providing recipients with direct control over assets. The description includes one or more family members contribute assets to the FLLC or FLP. The FLLC or FLP has two classes of owners: general partners (GPs) and limited partners (LPs). Any discounts properly reducing the value of LP units reduce the gift or estate tax exemption used, or gift or estate tax paid, in transferring those units. Assets contributed to the FLLC or FLP will receive certain discounts which may be appropriate in the valuation of LP units.
Recapitalize S Corporations
Create voting and nonvoting stock and obtain valuation discounts and obtain creditor to liability protection.
Fractionalize
Sell LP interests to Intentionally Defective Irrevocable Trust (IDIT) in exchange for promissory notes to discount estate.
Stage III Move Assets & Provide Liquidity
Annual Exclusion
Maximum annual gift tax exclusion.
Use of Applicable Estate Tax and Generation Skipping Transfer Tax Exemption
Maximize the estate tax exclusion amounts and GST exemptions.
Intentionally Defective Irrevocable Trust (IDIT)
An Intentionally Defective Irrevocable Trust which is drafted so that grantor will be treated as the owner of the
trust for income tax purposes but not for gift tax purposes. A proper estate planning freeze technique involves a
sale of limited partnership or member interests, usually for an installment note, to an IDIT. The value of the
assets is “frozen” at the value of the note received in the sale, so that the future appreciation in the value of the
assets sold to the IDIT will be transferred to the beneficiaries of the IDIT without gift or estate tax.
Grantor Retained Annuity Trust (GRAT)
Grantor Retained Annuity Trust. A GRAT is a gift trust which essentially enables you to place an assets into a
trust, retain an interest in the property (i.e., income stream) for a stated period of years and at the end of the
period transfer the asset to the remainder beneficiaries (typically your children). Since you retain an interest in
the property the value of the gift is reduced.
Qualified Personal Residence Trust (QPRT)
Qualified Personal Residence Trust. The QPRT provides a mechanism through which you could irrevocably
transfer your residence and/or vacation home to a trust, retaining a term interest, with your children as
the ultimate beneficiaries. During the term period term, the house would remain in your name and under your
control; thereafter, it would be given to the beneficiaries pursuant to the terms of the QPRT.
Irrevocable Life Insurance Trust (ILIT)
Irrevocable Life Insurance Trust. An ILIT is a specific type of irrevocable trust. Typically, an ILIT provides for
distribution of trust income and/or trust assets to or for the benefit of the grantor’s spouse or children. The trust
can also be an indirect source of liquid funds to the grantor’s estate. Ownership of a life insurance policy
(usually on the grantor’s life) is vested in the trust. There are two basic types of ILIT’s — funded and unfunded.
A funded trust is, funded with income-producing assets in addition to one or more life insurance policies. An
unfunded ILIT has as its sole asset a life insurance policy, usually on the grantor’s life.
Stage IV Charitable Planning
Charitable Remainder Trust
The Charitable Remainder Trust is an irrevocable trust which is a split interest trust because you designate
separate beneficiaries for its income interest and for its remainder interests. In general, with this type of trust,
you would retain an income interest in the trust for life (e.g., five percent annual income stream). The remainder
interest after death will belong to the charity.
Charitable Lead Annuity Trust
Charitable Lead Annuity Trusts permit you to leave a charitable beneficiary an annual annuity payment for
a term of years. You may designate as the charitable beneficiary a private foundation established by you and
controlled by your descendants or a donor advised fund of which your descendants could be the advisor and
avoid significant estate taxes.
Private Foundations
Private Foundations permit you to involve your family in charitable decisions, control charitable assets and
donation decisions; Obtain significant income tax deductions; Remove assets from your taxable estate.
Stage V Asset Protection
Qualified Retirement Plans
Qualified retirement plans are a vehicle for the successful business owner and professional to save for
retirement. Qualified retirement plans provide for substantial tax deductions today and tax advantaged income
in the future. A properly designed qualified plan will help you keep more of what you earn.
International Asset Protection Trust
One of the most important pieces to any sophisticated asset protection plan is the international asset protection
trust (IAPT). An IAPT can offer the highest level of asset protection available under current law, and enables an
individual to establish a “start-over” fund in the event of unforeseen misfortune. This level of asset protection is
achieved through a variety of components found in certain foreign jurisdictions which permit the creation of a
“Self-Settled Spendthrift Trust” which is exempt from the Settlor’s claims. The IAPT can be effectively funded
with almost any type of asset. These structures can hold assets in any jurisdiction even the U.S. These transactions are reportable to the IRS but not taxed. These foreign jurisdictions do not recognize U.S. court judgements; do not allow U.S. attorneys to prosecute claims and will bar any claims in which a creditor failed to bring the action within 1-2 years from the date of the transfer. IAPT allows flight provisions which permit the trustee, and the “Trust Protector” to monitor the trust assets and immediately move them to a similar protective foreign jurisdiction in the event it appears the assets are threatened in any way.
International Private Placement Variable Life Insurance
In addition to the traditional benefits afforded by life insurance (tax-free accumulation of assets, tax-free policy
loans and tax-free death proceeds) foreign insurance companies have developed investment-oriented contracts
which provide lower fee structures. Such life insurance policies provide you with the opportunity to achieve
tax-free accumulation in your investment portfolio.
Captive Insurance Companies
A captive is a insurance company organized primarily for the purpose of insuring or reinsuring the liabilities of the business owners. The structures provide federal, state and international tax advantages. They can be established either domestically or internationally.
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