Situation
A 75-year-old woman’s estate included $16 million of commercial real estate held in separate limited liability companies (LLCs). She sought to avoid estate taxes while retaining an income stream and control of the LLCs. We transferred nonvoting ownership units in her LLCs to an irrevocable trust, in part by gift and in part by installment sale. She retained the voting LLC units.
Result
The assets gifted to the irrevocable trust, including the future appreciation of the trust assets, are estimated to save estate taxes in excess of $8 million.