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12. Parent(s) Trust for Heirs
Promissory
Note
Paid with Life Insurance Co
Charity Insurance
Proceeds
Note
InKnowVision 12
13. $40M estate
$36.5M is illiquid commercial real estate
Real estate is:
◦ Devalued
◦ Distressed
◦ Needs updating
◦ Needs rent increases
◦ Liability issues everywhere
Clients are 88 (and dying) and 85 and
uninsurable
If they die, estate tax of $9M-$16M
What should they do?
InKnowVision 13
14. Sale of RE assets
Parent(s) Trust for Heirs
$27M Note
Not
Note
e
Assets were owned in a holding company
Recapitalized and sold at a 25% discount.
InKnowVision 14
15. Parent(s) Trust for Heirs
Buys Insurance
Not on
e
child/children
Cash flow pays note
payment and insurance
premium
Life Insurance Co
InKnowVision 15
16. Parent(s) Trust for Heirs
Owns
Real Estate
Pays Premium
Note
100% Charitable Deduction
•Reduce estate tax
Charity •Use disclaimer
•Use TCLAT
InKnowVision 16
17. Parent(s) Trust for Heirs
Owns all assets
less cost of
insurance
Promissory
Note
Paid with Life Insurance Co
Charity Insurance
Proceeds
Note
InKnowVision 17
18. Charity holds note from estate
Long term
Interest accrues
Low interest rate
Collateralized?
What is value of note
How much would charity take for cash today?
InKnowVision 18