Estate Tax

Saving $10 million in estate tax

We represented the wife and children of a family who came to us after the father had passed away. We soon discovered that the father hadn't done any estate planning. He didn't even have a Will. As a result, the estate passed under the laws of intestacy, which meant the children would receive one-half of the estate, and the wife the other half. However, although the wife's share would not be taxed, there would be a 50% estate tax on any distributions to the children, reducing their inheritance by half. The estate tax would have been $10 million.

To avoid the payment of this tax, we created a charitable lead annuity trust and a foundation. Although it delayed the children's receipt of their inheritance for 8 years, the result was a complete success, with a total estate tax savings of $10 million.

International Tax

Protecting assets with an offshore structure

A citizen and resident from a South American country came to us for help. His country had recently enacted a long-arm tax regime designed to tax their citizens on income earned on assets owned outside of the country. The tax impact on our client would have been substantial. With local counsel, we designed an offshore structure that legitimately avoids the reporting and tax requirements under this new tax regime.


Frank T. Adams