Chapter I: The Proposed Estate Plan

• Review of Important Concepts
• Proposed Estate Plan (Will Arrangement)
• Unified Credit Trust
• Life Insurance Trust Arrangement
• Marital QTIP Trust Rather than Outright Marital Bequest
• Planning for the $1,060,000 Generation Skipping Transfer (GST) Exemption
• Utilizing the Estate Assets to Provide Income to the Surviving Spouse
• Proposed Estate Plan (Will Arrangement) (Assumes Mrs. Kugler Predeceases)
• Unified Credit (Bypass) Trust Life Insurance Trust Arrangement
• Marital QTIP Trust Rather than Outright Marital Bequest
• Planning for the Generation Skipping Transfer (GST) Exemption
• Utilizing the Estate Assets to Provide Income to the Surviving Spouse
• Creating a New Asset to Help Fund the Payment of Estate Settlement Costs (Regardless Which Spouse Dies First)
• The Business Owner Who Wants to Purchase Life Insurance and Minimize Gift Tax Concerns via Split Purchase with Corporation
• Private Split Dollar
• Planning for Future Estate Appreciation

• Planning for the Payment of the Estate Tax for the Surviving Spouse with Children
• Planning for the Estate Owner with No Children
• The Married Estate Owner with Children from a Previous Marriage Providing for Two Different Families
• Life Insurance in lieu of a Direct Bequest to the Children in a Large Estate
• Outright Bequest Versus Bequest via Trust Arrangement
• Estate Planning Considerations for Resident and Non-Resident Aliens
• The Estate Transfer to a Non-Citizen Spouse
• Creating a Living Trust to Save Probate Fees
• Too Much Joint Property and Problems Allocating Assets to Fund Unified Credit Trust
• The Planned Disclaimer
• Post-Mortem Planning: Utilizing the Previously Taxed Property (PTP) Credit for the Terminally Ill Surviving Spouse
• Creating a New Asset to Cover the Growing Estate Tax
• The Expensive Price of Installment Payment for Federal Estate Taxes (IRC Section 6166)
• Special Use Valuation for Qualified Real Property
• Funding Analysis of Various Methods to Pay Estate Settlement Costs
• Using a Qualified Retirement Plan to Fund a Unified Credit Trust
• Benefits Payable to a Surviving Spouse via a Conduit QTIP Trust

• The Majority Interest Gift which Qualifies for the Minority Interest Discount
• Lifetime Gift of Business to Enable Both Spouses to Obtain Minority Interest Discount
• Gifts to Family Members via the Family Limited Partnership Arrangement
• Gifting the General Partner Interest and Retaining the Limited Partner Interest The Family Limited Partnership in Lieu of an Irrevocable Life Insurance Trust
• Utilizing a Qualified Retirement Plan to Enhance Your Estate Distribution
• The Purchase of Survivorship Life Insurance in a Qualified Retirement Plan for Subsequent Transfer to an Irrevocable Life Insurance Trust
• The Advantages of Using Life Insurance to Maximize the Use of Unified Credit and/or Annual Exclusion Gifts
• The Gift to the Terminally Ill Spouse to Utilize Unified Credit and also Plan for Basis Step Up of Gifted Assets
• Qualified Family-Owned Business Deduction (Married Business Owner Dies First)
• Qualified Family-Owned Business Deduction (Non-Business Owner Spouse Dies First)

• Qualified Personal Residence Trust (Residential GRIT)
• The Minority Interest QPRT
• The Qualified Personal Residence Trust and the Sale of the Residence and Rollover to a GRAT
• Using a Grantor Trust as the Remainder Interest Beneficiary of a QPRT
• Funding Life Insurance Premiums via a QPRT
• The Non-Family Gift via GRIT
• Grantor Retained Annuity Trust
• The Zero Minimum Gift GRAT (Funded with a Discounted Income Producing Asset)
• Short Term Zero Minimum Gift GRAT (Funded with a Non-Income Appreciating Asset)
• Funding Life Insurance Premiums via a Minimum Gift Short Term GRAT
• The Advantage of the Short Term Rolling GRATs
• The Charitable Short Term GRAT
• The Advantages of Distributing Limited Partnership Assets to Fund the Annuity Payout in a GRAT
• Sale/Gift of an Income Producing Asset to a Grantor Trust
• Sale/Gift of a Non-Income Producing Asset to a Grantor Trust
• Funding Life Insurance Premiums via a Gift/Sale to a Grantor Trust
• Self Cancelling Installment/Balloon Note (SCIN)
• The Private Annuity
• Using IRS Mortality Tables for the Estate Owner with Less Than Standard Life Expectancy

• A Unified Credit Gift to a GST Life Insurance Trust Utilizing Gift Splitting and Single Life Coverage
• A Unified Credit Gift to a GST Life Insurance Trust Utilizing Gift Splitting and Survivorship Life Coverage
• Limiting the Crummey Withdrawal Right to $5,000 for the Multiple Skip GST Life Insurance Trust
• Using the Hanging Power of Appointment to Qualify a GST Gift for the Annual Exclusion
• Qualifying for Both the Gift Tax Annual Exclusion and the GST Annual Exclusion via the "Direct Skip" Trust
• Separate GST Life Insurance Trusts for Children and Grandchildren
• The Predeceased Parent and the GST Problem for Irrevocable Life Insurance Trust
• The Deflected Inheritance

• Selecting Assets to Fund Lifetime Charitable Gift
• Charitable Remainder Unitrust
• Charitable Remainder Annuity Trust
• Charitable Remainder Trust with Wealth Replacement Option
• Net Income Make-up with Charitable Remainder Unitrust (NIMCRUT)
• Charitable Lead Annuity Trust (Funded with Discounted Income Producing Asset)
• Charitable Lead Annuity Trust (For a Term Certain) (Funded with a Non-Income Producing Appreciating Asset)
• Funding Life Insurance Premiums via Gift CLAT
• The Advantage of Using Qualified Plan Assets or IRAs to Fund Charitable Bequests
• Funding the Death-Time Charitable Gift with Life Insurance
• Testamentary Charitable Remainder Trust (Funded via Qualified Retirement Proceeds)
• Testamentary Charitable Remainder Trust (Funded via Capital Asset)
• Testamentary Charitable Lead Annuity Trust (For a Term Certain)
• Private Charitable Foundations

• The Tax-Free Real Estate Split-off
• The Limited Liability Company
• Equalizing the Estate Distribution while Passing the Business to the Child Active in the Business
• Using a 303 Stock Redemption to Downsize the Business to Equalize the Estate Distribution to the Non-Business Children
• Transferring the Family Business to the Non-Active Spouse or to the Active Children
• The Non-Leveraged ESOP
• The Leveraged ESOP
• The Stock Redemption Buy/Sell
• Family Corporation Buy/Sell
• The Corporation Cross-Purchase Buy/Sell
• The Partnership Cross-Purchase Buy/Sell
• The Insured "S" Corporation Buy/Sell and the Step-up in Cost Basis to the Surviving Stockholder
• Cross-Owned Life Insurance to Fund a Stock Redemption (Wait and See Buy/Sell)
• Structuring a Family Limited Partnership to Help Your Children Purchase Your Co-Stockholder's Business Interest

• Transfer of Corporate Life Insurance to Co-Stockholder
• Key Person Life Insurance
• The Split Dollar Life Insurance Plan
• The Non-Qualified Deferred Compensation Plan
• The Salary Continuation Plan
• The Combination Plan: Key Person, Split Dollar, and Supplemental Retirement Plan
• Executive Bonus Plan

Chapter I: The Advantages of Tax Sheltered Assets

• Tax Deductible IRA vs. After-Tax Savings for Retirement
• Tax Deductible IRA vs. Non-Deductible Tax Deferred Annuity
• Tax Deductible IRA with After-Tax Investment of IRA Tax Savings
• Tax Deductible IRA vs. Non-Deductible Roth IRA The Roth IRA vs. a Tax Deductible IRA and Supplemental Investment of Tax Savings
• The Roth IRA versus a Tax Deductible IRA with Benefits Payable Via the Uniform Distribution
• The Advantages of Starting Retirement Contributions Early
• The Roth Advantage of No Required Lifetime
• Participating in Both a Qualified Retirement Plan and a Roth IRA
• The Cumulative Results of Maximum Contributions to Several Retirement Plans
• Additional Individual Contributions After Age 50
• Credit for Low and Middle Income Taxpayers for Contributions to Qualified Retirement Plans and IRAs

• Review of General Distribution Concepts
• Options Upon Separation From Employment
• Separation from Employment and the Potential 20% Mandatory Withholding Requirement
• In-Service Distributions
• Loans from Qualified Plans - Deemed Distributions
• Excess 401(k) Contributions and Deferrals Structuring Pre Age 59½ Withdrawals Under IRC Section 72(t) and IRS Notice 89-25
• Systematic Withdrawals From an IRA Prior to Age 59½
• The Advantages of Splitting Your IRA and Taking Systematic Withdrawals Prior to Age 59½
• The Difference Between Distributions From a Profit Sharing Plan and an IRA for the 10% Penalty Prior to Age 59½
• Taking Distributions Prior to 59½ and a Subsequent Desire to Terminate Distributions
• Distributions Prior to 59½ and a Subsequent Desire to Increase Distributions
• Change of Distribution Prior to 59½ Due to Divorce - Qualified
• Domestic Relations Orders (QDRO's)
• Termination of Employment During a Year in Which Account Values Have Either Substantially
• Increased or Decreased in a Non-Self Directed Defined Contribution Plan

• Severance of Employment after age 55 and Subsequent Withdrawals From the Qualified Plan
• Distributions Between Age 59½ and 70½
• Electing Special Ten Year Averaging or Rollover to an Individual Retirement Account
• Voluntary Contributions - Cost Basis
• Transfer From One IRA to Another - Rules and Restrictions
• Distributions From Tax Sheltered Annuities (403(b) Plans) Before Age 70½

• Selecting a Lump Sum or Annuity Option
• Distributions from a Defined Benefit Plan Where a Lump Sum is not Available
• Forgoing the Joint and Survivor Annuity from your Qualified Plan, Elect a
• Life Annuity Option and Insure the Survivor Benefit
• Structuring the Retirement Assets to Provide for Children of the Married Plan Participant
• Options for a Plan Participant with Creditor Problems

• Required Beginning Date (RBD)
• Minimum Required Distributions (MRDs)
• Required Beginning Date - Taking Distribution At Age 70½ Rather Than
• Deferring Until April 1st of the Following Year
• Required Beginning Date - No Distribution at Age 70½ - Two Distributions the Following Year
• Minimum Required Lifetime Distributions at Age 70½ with Spouse as Beneficiary
• Minimum Required Lifetime Distributions at Age 70½ with Younger Spouse as Sole Beneficiary
• Minimum Required Lifetime Distributions at Age 70½ with Non-Spouse Beneficiary
• Distributions at Age 70½ From A Qualified Plan and Several Individual Retirement Accounts
• Required Beginning Date for Plan Participant with a 242(b) Election
• Failure to Commence Distributions at the Required Beginning Date
• Doing A Spousal IRA Rollover Years After the Death of the IRA Owner
• Post Death IRA Rollovers by Subsequent Surviving Spouse
• Establishing a Qualified Plan For An Individual Over 70 1/2

• What is the Significance of a Designated Beneficiary?
• Waiver of My Spousal Rights to Qualified Retirement Benefits
• Designated Beneficiary at the Required Beginning Date
• Changing Beneficiaries after the Required Beginning Date
• Flexibility with Designating Different Distributions for Different Accounts

• Death Before the Required Beginning Date (RBD) with Younger Spouse as Beneficiary
• Death Before the Required Beginning Date (RBD) with Pre-59½ Spouse as Beneficiary
• Death Before the Required Beginning Date (RBD) with Older Spouse as Beneficiary
• Death After the Required Beginning Date (RBD) with Spouse as Beneficiary
• The Use and Advantage of the Uniform Distribution Period Table to the Surviving Spouse and Heir
• Death Before the Required Beginning Date with Non-Spouse Designated Beneficiary
• Death After the Required Beginning Date with Non-Spouse Designated Beneficiary
• Death Before the Required Beginning Date with Multiple Designated Beneficiaries - Distribute
• Death After the Required Beginning Date with Multiple Designated Beneficiaries - Divide
• Post Death Distribution Planning by Designated Beneficiary - Distribute, Disclaim and/or Divide
• Death Before the Required Beginning Date with No Qualifying Designated Beneficiary
• Death After the Required Beginning Date with No Qualifying Designated Beneficiary

• Benefits Payable to a Surviving Spouse Via a Traditional IRA Qualified Terminal Interest Property (QTIP) Trust
• Benefits Payable to a Surviving Spouse Via a Conduit IRA Qualified Terminal Interest Property (QTIP) Trust
• The Conduit IRA QTIP Trust vs. a Traditional IRA QTIP Trust
• The Use and Advantage of a Spouse Redetermined Life Expectancy
• The Significance of How Benefits are Payable to a Surviving Spouse
• How Benefits are Payable to the Surviving Spouse Determines the Duration of the Subsequent Payout to the Non-Spousal Beneficiary
• Using a Qualified Retirement Plan to Fund a Qualified Domestic Trust (QDOT)
• Benefits Payable to a Surviving Spouse Via A Disclaimer or Credit Shelter Trust
• Benefits Payable to a Unified Credit Trust for the Surviving Spouse and Children
• The Conduit IRA Bypass Trust vs. a Traditional IRA Bypass Trust
• Benefits Payable to Non-Spouse Beneficiaries (Credit Shelter or Other Trusts)
• Benefits Payable to Grandchildren Trusts Utilizing the Maximum Generation Skipping Transfer (GST) Tax Exemption
• Paying Estate Taxes on Qualified Retirement Plans and IRAs
• Life Insurance to Pay Estate Tax on the Qualified Plan Death Benefit
• Funding your Pecuniary (Dollar Amounts) Bequests with your IRA or Qualified Plan
• Should I Fund my Credit Shelter Trust with a Roth or a Traditional IRA?
• Death Bed Planning Via IRA Conversion to a Roth IRA
• The Advantage of Using Qualified Plan Assets or IRAs to Fund Charitable Bequests
• Testamentary Charitable Remainder Trust (Funded with Qualified Retirement Proceeds)

• Elongated Distribution Planning Techniques
• Analysis of Stretch Out IRA Under Different Spousal Beneficiary Options

• Conversion to a Roth IRA Using the IRA Assets to Pay the Tax
• Conversion to a Roth IRA at a Younger Age
• Re-Characterization From an IRA to a Roth IRA and Back to an IRA Again

• Life Insurance in a Defined Contribution Plan
• Tax Aspects of Life Insurance in a Defined Contribution Plan
• Life Insurance in a Defined Benefit Pension Plan
• Distribution Options with a Life Insurance Policy as Part of your Qualified Retirement Plan
• Utilizing a Qualified Retirement Plan to Enhance your Estate Distribution
• The Purchase of Survivorship Life Insurance in a Qualified Profit Sharing Plan for Subsequent Transfer to an Irrevocable Life Insurance Trust
• Using a Qualified Retirement Plan or IRA Death Proceeds to Fund a Charitable Remainder Trust with a Wealth Replacement Option
• Using Life Insurance as a Wealth Replacement Option for a Gift at Death of Qualified Plan or IRA Owner
• Section 412(i) Defined Benefit Plan

• Locate and Read IRA Documents and Beneficiary Designation Forms
• Distribution of Employer Securities
• Pledging, Assigning or Alienating Qualified Retirement Plan Assets
• Pledging, Assigning or Alienating Qualified Retirement Plan Benefits for a Qualified Domestic Relations Order (QDRO)
• Excess Nonqualified Deferred Compensation Programs

• Introduction
• Lifetime Minimum Required Distributions - Uniform Lifetime Distribution Table
• Joint Life Expectancy Table - Used when surviving spouse is sole beneficiary and more than ten years younger
• Single Life Expectancy Table - IRS Regulation 1.72-9 Table V
• Equal Periodic Payments Under IRS Code Section 72(t)
• Defined Benefit Distribution Table Ten Year Averaging Table
• Typical Beneficiary Mistakes
• Considerations Regarding Conversions to a Roth IRA