Administration of numerous estates that required the filing of estate tax returns
Handling the administration of numerous estates that required the filing of estate tax returns, including estates that involved the credit for tax on prior transfers, a qualified domestic trust for a non-U.S. citizen surviving spouse, and family limited partnerships.
Advising clients on use of trusts designed to save gift and estate taxes
Advising a number of clients on the use of "zeroed-out" grantor retained annuity trusts designed to take advantage of low interest rates and transfer assets to children without the imposition of gift taxes, as well as intentionally defective grantor trusts and generation-skipping transfer (GST) trusts.
Defense of client in tax-free split in family-held businesses
Defended client in tax-free split of $1.5 billion in family-held businesses with substantial real estate holdings and ownership of NFL franchise. The case spawned three lawsuits and involved many consultants in areas of accounting, tax planning and estate planning.
Drafting of various trusts and estate documents
Drafting many simple and complex wills and trusts, revocable trusts, charitable remainder trusts, charitable lead trusts, grantor retained annuity trusts, grantor retained unitrusts, qualified personal residence trusts, and numerous other tax-driven instruments.
Estate Administration
Representing administrators and executors in the administration and probate process including probate of wills, estate and probate litigation matters and preparation of federal estate and state inheritance tax returns.
Estate Planning
Drafting wills, trusts (including charitable trusts, grantor trusts, asset protection trusts, and personal residence trusts), powers of attorney, advanced health care directives, and living wills.
Formation of family limited partnerships and LLCs
The preparation of family limited partnerships and limited liability companies, using the laws of the State of Alabama, Georgia, Delaware, South Dakota, and Alaska.
IRS audits and Tax Court litigation matters
Numerous IRS audits and Tax Court litigation matters involving estates ranging from $1 million to $200 million.
Pre-marital Agreements
The preparation of numerous pre-marital agreements.
Preparation of estate and gift tax returns
Preparation of numerous estate and gift tax returns involving transfers ranging from $1 million to in excess of $200 million
Preparation of IRS private letter ruling requests
Preparation of numerous private letter ruling requests to the Internal Revenue Service involving various gift, estate and generation-skipping tax issues.
Preparation of tax-oriented wills, trusts and business entities
Representation of families on a routine basis in preparation of appropriate tax-oriented Wills, Trusts, and family business entities.
Probate Court Litigation
Probate Court litigation in over 40 contested matters involving wills, trusts, conservatorships, and probate matters
Representation of beneficiaries in intra-family dispute
Representing three beneficiaries of trusts created by their grandfather in an intra-family dispute, successfully causing the trustee to resign and recovering assets on behalf of the trusts.
Representation of Executors
Representation of Executors in handling the administration of estates and dealing with the IRS in estate and gift tax audits and litigation.
Trusts
Rhone v. Adams, 986 So. 2d 374 (Ala. 2007)
Dismissal of putative class action against trustees of charitable trust based on absence of standing affirmed.
Neal v. Neal, 856 So. 2d 766 (Ala. 2002)
Summary judgment upholding settlement of dispute involving construction and management of trust affirmed.