A married couple with two children owned a significant closely held business. They wanted their daughter to inherit the business, with an equitable share of cash and other assets to their son, while avoiding estate tax exposure.
We recapitalized the business into 5 percent voting stock and 95 percent nonvoting stock. The husband gave his nonvoting stock to an irrevocable gifting trust. The trust used business distributions to pay for life insurance. Upon the wife’s death, the daughter will receive business stock and the son cash from the insurance.