Estate Planning

Planning for Intellectual Property

There are three basic types of intellectual property (IP): copyrights, trademarks and patents.   Copyrights do not protect ideas, but do protect the way those ideas are expressed.  Trademarks protect logos, slogans or other ways a business is identified.  Patents protect inventions. IP presents unique challenges for estate and business planning.  It is a difficult […]

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Estate of Powell-Rosebud…

Estate of Powell,, is a recent Tax Court case that illustrates how not to do it.  It involved perhaps the most aggressive deathbed  planning I have ever read about.  The decedent’s son, acting under a power of attorney that didn’t give him full authority to do the planning he undertook, transferred marketable securities to a

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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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