Proposed Wealth Transfer and Income Tax Deferral Transaction
STEP 1
The client creates a new limited partnership and initially funds it with all or some part of his or her current ownership interest in Sample Company, LLC. The client receives in return for his or her capital contribution of this interest in Sample Company a 99.9% limited partnership (“LP”) interest and a .1% General Partner (“GP”) interest.
STEP 2
The client creates one or more Irrevocable Trusts for the benefit of his or her descendants. Alternatively, the client may wish to use the current irrevocable trusts for their benefit.
STEP 3
Client sells his or her desired interest in the new LP in exchange for an installment note. The terms of the Note are interest only for 20 years, with a balloon principal repayment in year 20.
STEP 4
LP sells its interest in Sample Company to unrelated party for cash and/or short-term installment obligation. Preferably, this sale occurs more than two (2) years after the initial sale of the client’s LP interest to the Family Trusts. LP invests net proceeds in a diversified investment portfolio.
STEP 5
Family Trust(s) may purchase life insurance with additional investment earnings for additional wealth transfer savings.
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