Taxation & Estate Planning

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Overview

Taxation and Estate Planning

Connell Foley’s Tax and Estate Planning team, led by partner and nationally recognized estate planning attorney, Anthony F. Vitiello, Esq., provides highly tax efficient strategies for the transfer of wealth and reduction of estate, gift, and income taxes, as well as provides a diverse range of other services within the tax, trust, and estate practice area. 

Our team establishes structures ranging from tax efficient Wills to the most complex and esoteric estate planning constructs, all with the goal of minimizing tax and maximizing estate preservation opportunities for our clients. Put succinctly, we help our clients pass more assets to their heirs.  And if it comes time to be an advocate for our clients, whether against the Internal Revenue Service or involving litigation between beneficiaries and fiduciaries, our team provides our clients with vigorous representation. 

Our team not only maintains cutting edge knowledge in the tax and estate planning field, we actually develop new strategies and improve upon existing ones, so that our clients’ estate plans reap maximum tax savings. Once implemented, our team nurtures and oversees the plan through completion, whether it takes several months or many years. During that period, we adjust the plan to keep in step with changes that impact our clients’ financial legacy, as well as their intended goals.

Areas of Focus

Our team provides advice and vigorously represents our clients in the following areas of specialization on a regional, national, and international basis:

  • Estate and Gift Tax Planning
  • Estate Administration and Probate
  • Trust Administration
  • Tax Planning
  • Asset Protection Planning
  • Estate and Gift Tax Audits/Tax Controversy
  • Business Succession Planning
  • Estate Litigation

Who We Serve

Our group acts as a full service resource for a wide variety of clients, including:

  • High and ultra high net-worth individuals and families
  • Beneficiaries of estates and trusts
  • Executors of estates
  • Trustees of trusts
  • Business owners
  • Accountants
  • Other licensed professionals
  • Other attorneys (as specialists)

Representative Matters

Our group’s successful representations have included:

  • Provided advice relating to and implemented estate plans for clients with estates ranging in value from $5,000,000 to more than $1,000,000,000
  • Advised on tax and asset protection issues of an international family trust structure estimated at several billion dollars in value
  • Designed and implemented charitable giving techniques and family charitable foundations ranging in initial funding from $1,000,000 to over $10,000,000
  • Orchestrated the transfer of tens of millions of dollars of real estate out of a senior generation’s estate into dynasty trusts for multi-generational wealth transfer without incurring gift tax
  • Represented and advised hundreds of executors and families in the administration of decedents’ estates, including those with multi-state and multi-national components involving unique, varied, and substantial assets and complex tax and non-tax issues 
  • Developed and implemented various off-shore asset protection trusts using Bahamian, Cook Islands, and Swiss components
  • Advised multinational estate planning clients in international estate planning and created structures for the avoidance of U.S. estate tax consequences for non-resident aliens with U.S. estate tax issues

Successfully defended against numerous audits and civil tax prosecutions including:

  • settled an Internal Revenue Service gift tax litigation with an asserted $20,000,000 in gift tax, penalties, and interest for less than $300,000
  • settled an asserted $5,000,000 in income tax, penalties, and interest with the California tax authority for $200,000
  • settled a case in which the taxpayer was charged with a civil tax fraud deficiency in excess of $600,000 for 15 cents on the dollar
  • successfully defended and settled numerous family partnership/LLC gift and estate tax audits for substantial discounts
  • Designed multiple private and third-party insurance premium financing transactions ranging from $10,000,000 to $100,000,000 in insurance death benefits
  • Transferred closely held businesses to younger generations at significantly discounted values

The Tax and Estate Planning Group has the size, depth, and expertise to properly represent our clients in all of the group’s areas of concentration.