500 N. Akard St., Suite 2200, Dallas, TX 75201

Grady Dickens

Purgatory-The Crucial Time Between Date of Death and Appointment of Executor

A colleague of mine, who was named as executor under the will, is faced with the not uncommon circumstance of managing the two children heirs who don’t like each other.  He can’t yet act for the estate, but there is the real possibility that things could escalate into an ugly and unfortunate situation.  In these …

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Variable Prepaid Forward Contracts-A Monster Planning Idea

Variable prepaid forward contracts (VPFC) are used to diversify a concentrated position in a publicly traded stock, and defer tax on the sale.  Here is how they work: taxpayer (i) pledges the stock to a counterparty, (ii)  receives cash equal to a percentage of the fair market value of the stock (typically 75-85% of the …

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A New Planning Opportunity with Charitable Remainder Trusts

Charitable remainder trusts (“CRTs”) are split interests trusts, with the taxpayer retaining an income interest and charity receiving the remainder.  The CRT often is used to defer gain on the sale of highly appreciated property.  The taxpayer receives an income deduction for the value of the remainder interest going to charity and defers the capital …

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Exiting an S Corporation is a Sticky Wicket

I generally don’t recommend structuring a business as an S corporation.  Unlike LLCs and partnerships, the S corporation rules (i) restrict the number and type of owner, (ii) provide no flexibility in allocating income and loss, (iii) do not allow a step up of the assets at death of the shareholder and (iv) unlike other …

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The Beginning

My dad was a banker, my mom a homemaker.  Dad died of an aneurysm the morning after I graduated high school.  His will left everything in a trust for mom’s benefit, with the bank as trustee.  She was devastated over his loss, but also felt powerless, in part, because of the way dad structured things. …

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