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Taxation and Estate Planning

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Overview

Connell Foley’s Taxation 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. From guiding clients through the complicated maze of federal estate taxation issues to establishing sophisticated approaches to transferring assets, our goal is to preserve our clients’ wealth. We offer counsel in the full range of tax, trust and estate services.

Our lawyers establish structures ranging from tax-efficient wills to the most complex and esoteric estate planning constructs. In each case, the goal is to minimize tax burdens and maximize opportunities for estate preservation. If needed, we also vigorously advocate for our clients, whether against the Internal Revenue Service or in litigation matters between beneficiaries and fiduciaries.

Our client relationships are close and longstanding, helping us to proactively identify and meet clients’ changing needs. Understanding the dynamic of a family or closely held business is paramount. Whether over several months or years, or across generations, we nurture and adjust each plan to align with changes that shape the client’s financial legacy and achieve their goals.

Areas of Focus

Connell Foley’s Taxation and Estate Planning group provides advice and vigorous representation in the following areas of focus 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
  • Charitable Giving and Family Foundations

Our Clients

We act 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 lawyers (as specialists)

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

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 million to more than $1 billion
  • 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 million to over $10 million
  • 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
  • Designed multiple private and third-party insurance premium financing transactions ranging from $10 million to $100 million in insurance death benefits
  • Transferred closely held businesses to younger generations at significantly discounted values

We have also successfully defended against numerous audits and civil tax prosecutions including:

  • Settled an Internal Revenue Service gift tax litigation with an asserted $20 million in gift tax, penalties, and interest for less than $300,000
  • Settled an asserted $5 million 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

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