Planning for the Freeze: Trust & Estate Planning to Freeze Asset Values

Tuesday November 21, 2017

“Asset freezes” transfer future appreciation in a closely-held company or other asset from a senior generation to a junior generation, reducing the tax exposure of the senior generation and providing that any appreciation will be taxable at the generally lower rates of beneficiaries.  Asset freezes use a variety of trusts and techniques to achieve this shift in taxable appreciation.  Because freezes are subject to abuse, they are frequently challenged by the IRS.  But if carefully planned, drafted, and administered, asset freeze platforms are effective tools for tax reduction while the senior generation still retains some income or other benefit of the asset.  This program will provide you with a real world guide to the techniques and traps, opportunities and limits of asset freezes.

Handout Materials Will be Emailed to You Prior to the Seminar

Starts 12:00 p.m.
1.0 MCLE Credit Hours


·         Asset freeze platforms and techniques in trust and estate planning – and planning traps

·         Use of retained interest trusts to shift asset appreciation – GRATs, GRITs, GRUTs

·         Installment note sales of closely-held companies to heirs

·         Use of self-cancelling installment notes and private annuities

·         Qualified Personal Residence Trusts

·         Income tax consequences of asset freezes


Missia H. Vaselaney, Taft, Stettinius & Hollister, LLP – Cleveland

Michael Sneeringer, Porter Wright Morris & Arthur LLP – Naples, Florida