Wealth and Law

Brent chats with Gary Pattengale about how clients can use after-tax strategies to improve their investing and planning outcomes. They discuss things like Roth IRAs, utilizing losses, counseling clients on the complexity, and helping people make informed decisions. Gary Pattengale serves as a Senior Vice President, Advanced Planning Specialist and Wealth Advisor in Mesirow Wealth Management. Gary acts a centralized, specialized resource advising clients on tax implications and strategy considerations when building comprehensive financial plans. Gary has over 30 years of experience in the financial services industry. Prior to joining Mesirow in 2024, Gary helped individuals, families and entities with their investment and financial planning needs as well as helping corporate executives and key employees navigate their stock-based compensation plans at companies such as Corient and Northern Trust. He also served in various accounting and auditing roles. Gary earned a Bachelor of Science in Accounting from Northern Illinois University and has also earned his CERTIFIED FINANCIAL PLANNER®  designation and has previously held the Certified Public Accountant certification. Gary can be found at: Gary Pattengale | Mesirow Employee Bio This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/.

Brent chats with Darren Case about what planning looks like this year for ultra high net worth families. They discuss how “basic” planning is key, GST tax planning, using general powers of appointment, trust protectors, intentionally defective grantor trusts, structuring trust flexibility, family limited partnerships, and more! Darren is a shareholder in the law firm Tiffany & Bosco, PA, in Phoenix, AZ. He assists families and individuals in the areas of estate planning, probate, and tax, and is the Co-Author (with Brent Nelson and TJ Ryan coincidentally) of the Arizona Estate Planning and Probate Handbook, published by Thomson Reuters – West. Darren is experienced in a broad range of planning techniques, including traditional wills and revocable trusts, along with more sophisticated planning strategies such as insurance trusts, residence trusts, “defective” grantor trusts, generation-skipping or dynasty trusts, charitable trusts, split-interest trusts, family limited partnerships and intra-family sales and loans, etc. He assists clients by providing tax and estate planning services specifically tailored to each individual client, whether it is a client who has amassed substantial wealth or those who are in the process of accumulating such wealth.  Darren is also experienced in the area of probate and trust administration and litigation, having worked on simple to complex trust and estate matters, and everything in between. Darren attended Arizona State University for his undergraduate studies, where he received his Bachelors of Interdisciplinary Studies in business and communication. He received his law degree from Chapman University, graduating with an emphasis in taxation, and was the Tax Law Emphasis Honors Graduate of his class. In addition to his law degree, Darren received his Master of Laws in Taxation, with a Certificate in Estate Planning, from Georgetown University. Darren’s firm bio and contact information are available at https://www.tblaw.com/attorneys/darren-t-case/. This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/.

Brent chats with Daniel Yoo about the ways that AI is (and is not) changing the world of wealth management. They talk about innovations, the current state of the AI market, how AI can be used in bespoke ways, and limitations of AI that are still yet to be solved. Daniel Yoo is the founder and CEO of FinMate AI, a custom Agentic AI development platform automating back office work as well as an AI Notetaker specifically designed for financial advisors. With a unique combination of financial advisory experience and technical expertise, Daniel spent seven years as a financial advisor at major firms, includingEquitable, TD Ameritrade, and Schwab, where he oversaw $800 million in client assets as a Senior Advisor. His educational background includes two bachelor’s degrees from UCBerkeley (Economics and Molecular Cell Biology with a specialization inDevelopmental Genetics) and a Master of Science from Johns Hopkins in Applied Economics, focusing on machine learning and AI for asset price predictions.After his advisory career, Daniel spent time in the fintech space before founding FinMate AI in May 2023. He continues to maintain his FINRA series licenses through FINRA’s MQP program and holds L&H and P&C insurance licenses. This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/.

Brent chats with Gray Edmondson about how debt can be a valuable tool in wealth transfers. They talk about recent tax court cases, how the AFR works, planning for cash loans, and then more complex transactions using debt to sell assets. Gray Edmondson is a Partner at Edmondson Sage Allen, PLLC  in Oxford, Mississippi. Gray practices in partnership, corporate, and individual tax planning; business transactions including mergers and acquisitions; business planning; tax controversy; estate and wealth transfer planning; probate; estate and trust litigation; asset protection; and charitable planning. Gray has conducted, authored, and directed numerous seminars for professional, academic, and civic groups on taxation, business, asset protection and estate planning. You can reach Gray at https://esapllc.com/s-gray-edmondson/ This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent chats with Brent Bowers about how he has strategically invested in land and built his real estate business. They discuss the tactics and address important risk management techniques to improve a real estate portfolio. Brent Bowers is an investor and coach with a focus on buying and selling vacant land. As an Army Officer with over 8 years of service, Brent was spending a great deal of time away from his family, and he knew he needed to make some changes in order to be more present with his wife and children. Brent began investing in real estate as a way to support his family while having more time to spend with them. In a short period of time, Brent was able to expand his business, hire a team, and (most importantly) spend quality time with his family while still working hard and helping others. Brent now helps other investors learn the ins and outs of buying land. This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent chats with Christine Alexis Concepción about how Americans in France can strategize around the thorny international tax issues they face. They talk about investing abroad, owning real estate in France, thinking about the cross-border tax world, and planning to succeed. Christine Alexis Concepción is an international tax and estate planning attorney and partner at Concepción Global, with offices in Miami, Madrid, and Paris. She advises high-net-worth individuals, entrepreneurs, and businesses on complex international and domestic tax matters, including income and estate tax planning, U.S. pre-immigration planning, expatriation, FATCA compliance, and multi-jurisdictional reporting. Christine has extensive experience advising individuals and families who have a connection between France and the U.S., guiding them through U.S.–France tax coordination, cross-border business structuring, real estate investing, and international estate planning. Multilingual in English, Spanish and French, Christine serves clients across the United States, Europe, Latin America, Africa, and the Middle East. To learn more about Christine and her work, connect with her on LinkedIn at https://www.linkedin.com/in/christineaconcepcion. This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent chats with Elizabeth Garlovsky about the ways trusts can be used in prenuptial agreements and divorce. They talk about structuring the trusts, common issues, and the results divorce can have on revocable and irrevocable trusts. Elizabeth (“Lizzy”) Garlovsky represents clients in matters related to estate planning and wealth transfer, probate, and estate and trust administration. She brings over 25 years of combined experience in private practice, the public sector, and as a wealth advisor for JPMorgan. Lizzy assists clients in preparing and implementing estate plans for a wide range of individuals and families. She also helps both individual and corporate fiduciaries administer trusts and estates at any stage, including through controversies both inside and outside of court. In addition, Lizzy frequently counsels heirs, legatees, and beneficiaries of estates and trusts of all sizes to advocate for their rights under will and trust documents or when no documents exist. In addition to her technical background and practical experience, Lizzy brings a unique holistic and human approach to every client matter through empathy and a commitment to understanding each client’s individual – and often very personal –situation before engaging in any representation. She recognizes the difficulty that clients routinely face when engaging a trusts and estates attorney, especially when emotions are high, and she is grateful for opportunities to make the difficult seem simpler for clients who are experiencing stress caused by trauma or grief, or by the anticipation of either. Lizzy is an active member of the trusts and estates community, and her community at large. She is a Fellow of the prestigious national American College of Trust and Estate Counsel (ACTEC) and is a member of their Fiduciary Litigation and Practice Committees. She also serves as the State Membership Recruitment Director for Illinois. Lizzy is a frequent lecturer and author on a wide range of trust and estate topics. She enjoys giving back to her peers by mentoring junior colleagues, both inside and outside of the firm. She served as an appointed Advisory Member of the Trust and Investment Committee for the Board of Directors of Chicago-based ATG Trust Company (acquired by Midland Trust Company) from January 2020 through May 2021 and currently serves as a member of the Board of Directors for the Illinois Institute of Continuing Legal Education. She is also a member of the Goodman Theater’s Spotlight Advisory Council. Lizzy provides pro bono legal services and supports related organizations and activities. She performs estate planning and related legal services for under-served individuals in her community and acts as a resource to various charitable organizations. In addition, from 2017 to 2021, Lizzy served as an elected member of the Board of Education for Township High School District 113 (Illinois). She served as President of the Board from May 2018 to May 2020, and served on the Board’s Policy Committee, Equity and Inclusion Committee, and as the Chair of the Human Resources Committee. Lizzy can be found here: Elizabeth A. Garlovsky – Harrison LLP This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/  

Brent chats about various income tax considerations that arise in estate planning and are more important now with a $15 million estate tax exemption. He talks about retirement accounts, real estate, partnership interests, and shares in corporations. This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent chats about portability and how it needs to fit within broader planning considerations, including income tax, estate tax, generation-skipping transfer tax, and overall structure. This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent chats about where attorney-client privilege begins, ends, and unexpectedly disappears. This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent chats about how trusts may actually be the best IRA beneficiaries now. This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent chats about what lawyers and advisers should hear when clients ask for “simple” estate plans. This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent chats about the ways that beneficiary designations can quietly, and unintentionally, override carefully drafted documents. This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent chats about why an unfunded trust is often a fixable planning gap and not an estate planning disaster. This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/  

Brent chats with Gary Fletcher about the upcoming FinCEN non-financed real estate transfer reports. The reports will make many professionals, including lawyers, subject to reporting obligations on many real estate transfers. This would reach into routine estate planning transfers. Brent and Gary discuss the details of the program, what transfers are caught in its net, and what to expect. Gary Fletcher is a Senior Partner at Frazer Ryan Goldberg & Arnold LLP in Tucson, Arizona. Gary practices tax accounting and estate planning, and is a Fellow in the American College of Trust and Estate Counsel (ACTEC). Gary can be found here: Gary L. Fletcher – Frazer Ryan Goldberg & Arnold, LLP This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent chats with Elizabeth Garlovsky about the unique challenges in representing married clients. They discuss some of the ethical considerations, including how to handle conflicts, when financial goals do not align, and ways to navigate topics like divorce. Elizabeth (“Lizzy”) Garlovsky represents clients in matters related to estate planning and wealth transfer, probate, and estate and trust administration. She brings over 25 years of combined experience in private practice, the public sector, and as a wealth advisor for JPMorgan. Lizzy assists clients in preparing and implementing estate plans for a wide range of individuals and families. She also helps both individual and corporate fiduciaries administer trusts and estates at any stage, including through controversies both inside and outside of court. In addition, Lizzy frequently counsels heirs, legatees, and beneficiaries of estates and trusts of all sizes to advocate for their rights under will and trust documents or when no documents exist. In addition to her technical background and practical experience, Lizzy brings a unique holistic and human approach to every client matter through empathy and a commitment to understanding each client’s individual – and often very personal –situation before engaging in any representation. She recognizes the difficulty that clients routinely face when engaging a trusts and estates attorney, especially when emotions are high, and she is grateful for opportunities to make the difficult seem simpler for clients who are experiencing stress caused by trauma or grief, or by the anticipation of either. Lizzy is an active member of the trusts and estates community, and her community at large. She is a Fellow of the prestigious national American College of Trust and Estate Counsel (ACTEC) and is a member of their Fiduciary Litigation and Practice Committees. She also serves as the State Membership Recruitment Director for Illinois. Lizzy is a frequent lecturer and author on a wide range of trust and estate topics. She enjoys giving back to her peers by mentoring junior colleagues, both inside and outside of the firm. She served as an appointed Advisory Member of the Trust and Investment Committee for the Board of Directors of Chicago-based ATG Trust Company (acquired by Midland Trust Company) from January 2020 through May 2021 and currently serves as a member of the Board of Directors for the Illinois Institute of Continuing Legal Education. She is also a member of the Goodman Theater’s Spotlight Advisory Council. Lizzy provides pro bono legal services and supports related organizations and activities. She performs estate planning and related legal services for under-served individuals in her community and acts as a resource to various charitable organizations. In addition, from 2017 to 2021, Lizzy served as an elected member of the Board of Education for Township High School District 113 (Illinois). She served as President of the Board from May 2018 to May 2020, and served on the Board’s Policy Committee, Equity and Inclusion Committee, and as the Chair of the Human Resources Committee. Lizzy can be found here: Elizabeth A. Garlovsky – Harrison LLP This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent chats with Natalie Perry about how non-grantor trusts can be used for income tax planning. They discuss the non-grantor trust tax rules, and how these trusts can be used to same both state and federal income tax by moving liquid assets to no tax states, using charitable deductions, and stacking qualified small business stock. Natalie Perry is a partner at Harrison LLP. For more than two decades, Natalie Perry has advised clients on strategies for achieving tax-efficient estate planning and income tax planning. She focuses her practice on advising high-net-worth individuals and their families on how to structure their estate plans creatively to accomplish their goals for the transfer of their wealth. As part of the process, Natalie helps educate clients on the importance of planning and the nuances of implementing the technique. As a registered certified public accountant (CPA) , Natalie brings a deep understanding of the complex and ever-changing tax laws her clients face. As an extension of her deep concentration in estate planning, Natalie also has experience crafting settlements to resolve trust disputes and representing trustees and beneficiaries in contested proceedings, including through mediation. She also advises trustees, executors, and beneficiaries in trust and probate administration, including handling IRS audits. Natalie started her career as a CPA before attending law school. For several years, she advised closely held businesses as tax consultant for a large public accounting firm. Natalie is a frequent speaker at professional education events for attorneys and accountants. Natalie was elected as a Fellow of the American College of Trust and Estate Counsel (ACTEC) in 2016. Her election to ACTEC was based on her outstanding reputation, exceptional skill, and substantial contributions to the estate planning community through lecturing, writing, teaching, and participating in bar activities. She is currently chair of the Communications Committee and an active member of the Business Planning Committee for ACTEC. Natalie is also a member of the board of directors of the Chicago Estate Planning Council. From 2018 through 2019, Natalie was Chairperson for the Hinsdale Hospital Foundation. Natalie can be found here: Natalie M. Perry – Harrison LLP This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent chats with Jenny Rozelle about what opportunities await law students interested in estate planning. They talk about their law school journeys, Jenny’s non-traditional entry into estate planning, the market and financial opportunities, and practicing in large or small communities. As one of the Owners of Indiana Estate & Elder Law, Jennifer (Jenny) Rozelle serves in a leadership role focusing on firm management, strategic growth, team development, and speaking locally and nationally on various estate and elder law topics. Jenny obtained her bachelor’s degree in both political science and history from Butler University and a Doctor of Jurisprudence from Indiana University Robert H. McKinney School of Law. Jenny is actively involved in several professional organizations, including the Indiana State Bar Association, where she participates in the Elder Law Section and the Probate, Trust, and Real Property Section. She is also a member of Lawyers with Purpose and the National Academy of Elder Law Attorneys (NAELA). Beyond her legal professional networks, Jenny dedicates time to Business Professionals of America, where she annually judges competitions for high school participants. Additionally, she serves as a Board Member for the Indiana Parkinson’s Foundation. Jenny can be found here: Meet Jennifer ‘Jenny’ Rozelle | Estate Planning Attorney This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent chats with Anna N’Jie Konte about what financial planning moves people should consider before the end of 2025. They talk about contributing to retirement plans and determining whether to make Roth conversions. They also discuss tax loss harvesting, charitable giving, and other tax sensitive options for planning. Anna N’Jie-Konte is a Certified Financial Planner and the founder of Poder Wealth Advisors. She is a wealth advisor, speaker, and entrepreneur dedicated to helping ambitious women build, enjoy, and protect their wealth. You can find Anna at About and on LinkedIn at https://www.linkedin.com/in/annanjie/. This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent chats with T.J. Ryan about important terms to make your trusts better. In this second part of that conversation, they discuss the importance of crafting the distribution provisions of a trust. They get into powers of appointment, spendthrift clauses, and what to do to anticipate incapacitated beneficiaries. T.J. is a Senior Partner at the Phoenix law firm of Frazer Ryan Goldberg & Arnold LLP. T.J.’s practice encompasses virtually all aspects of family estates, from estate and business planning, to probate and trust administration, to litigating contested estates – an area in which he has achieved a strong track record for positive results. A Fellow of the prestigious American College of Trust and Estate Counsel (ACTEC), T.J. Ryan focuses his practice on personal and business planning, including estate planning, estate administration, business entity formation, and trust and probate litigation. T.J. can be found here: T.J. Ryan, Trust & Estate Litigation and Estate Planning Attorney This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent chats with Eric Freeman about the real estate provisions in OBBBA. They talk about the importance of bonus depreciation, Opportunity Zone 2.0, New Market Tax Credits, and analyze what the industry could look like under this new tax regime. Eric Freeman is a Principal for BeachFleischman, where he leads the Real Estate Practice and serves as a member of the Tax Department. Eric has spent most of his accounting career focusing on real estate transactions and partnership taxation. He consults with clients on complex transactions, including multi-asset exchanges, mergers, consolidations, buy-outs, cost segregation studies, and transaction formation. His client base includes real estate developers, property owners, and property managers who operate with 2 million to 7 million square feet of real estate, both multi-family and commercial. Eric has a depth of knowledge and experience with international issues related to inbound and outbound real estate transactions. Additionally, he has written articles and provided numerous presentations and consultations on qualified opportunity zone funds. Eric has worked in public accounting since 2012, and he is a Certified Public Accountant licensed to practice in Arizona. Eric can be found here Eric Freeman | CPA | Principal Eric’s YouTube channel is here: Eric Freeman CPA – YouTube This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent and John Strohmeyer chat about sham trust schemes. They explain what the structures and hoped for results are and then break down why they do not work. They also speculate about why people buy these schemes. John Strohmeyer is the owner of Strohmeyer Law PLLC, in Houston, Texas. After earning his B.S. in Zoology from the University of Texas at Austin, John spent four years working for the Four Seasons Hotel in Austin, primarily as the Night Manager, before beginning his legal education. He earned my J.D. from the University of Texas School of Law in 2009, then earned a Masters of Law (also known as an “LL.M.”) in Taxation in 2010 from the New York University School of Law. While John’s time at NYU was the end of his formal education (at least for now), he has gone on to become Board Certified by the Texas Board of Legal Specialization in both Tax Law and Estate Planning & Probate Law. John has been recognized by his peers as a Fellow of the American College of Trust and Estate Counsel, named a Texas Super Lawyer by Texas Super Lawyers by Thompson Reuters in 2019, 2020, and 2021, a Rising Star by Texas Super Lawyers by Thompson Reuters in 2015, 2016, 2017, 2018, and 2019; “Rookie of the Year” in 2016 and Outstanding Substantive Committee Chair in 2017 by the State Bar of Texas Tax Section; a 2015-2017 Fellow of the Section of Real Property, Trust and Estate Law of the American Bar Association; and a Young Leader of the American College of Trust and Estate Counsel. John can be reached at [email protected], (713) 714-1249. His show is available on You Tube https://www.youtube.com/channel/UCDaKULB-A6Ru4tKfpZl8ozg and on Facebook https://www.facebook.com/strohmeyerlaw. This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent chats with Naomita Yadav about the tax and planning challenges of high-net-worth individuals migrating to the United States. They talk about global mobility, how tax can cause unexpected issues, and how one might plan for that transition effectively. Naomita Yadav is a partner in the private client and tax team of Withersworldwide. She has a diverse and well-rounded tax background, including experience in both income tax and estate and gift tax matters, which makes her particularly suited for families with existing complex trust structures. She also has experience with cross-border families as well as nuances of visa designations and the interplay with tax laws. Interestingly, her own family is situated in three continents. Naomita advises families with generational wealth in the context of changing circumstances and passage of time such as multi-generation wealth planning for family members who are beneficiaries of trusts settled by prior generations. This particular mix of experiences and knowledge enables Naomita to act as a proficient adviser for the globally mobile high net worth family. She also advises clients on tax, estate and succession planning related to cryptocurrencies and digital assets. Naomita received her bachelor’s degree from Yale, her MBA from the University of Michigan, and her juris doctorate from the University of Michigan Law School. Naomita can be found here Naomita Yadav | Private client and tax attorney | San Francisco | Withersworldwide This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent chats with Michael Preis, Chief Investment Officer at TCI Wealth Advisors, about how federal policy in the United States can affect investment strategies. They talk about the importance of planning and how a client focused approach is different from just pure asset allocation. Finally, they talk about crypto and where it fits into the current investment landscape. Michael Preis is the Chief Investment Officer at TCI Wealth Advisors, where his role is to help deliver an investment experience that gives their clients the greatest odds of success, anchored in long-term planning and rooted in time-tested principles. Michael is passionate about demystifying investment markets, but even more so about helping clients build the confidence that comes from a sound, disciplined approach. Prior to finding a professional home at TCI, Michael spent 15 years with Dimensional Fund Advisors serving the independent advice industry. He earned my MBA from the University of Texas at Austin and his undergraduate degree from the University of Southern California. He is also a CFA® Charterholder. Michael can be found here: Michael Preis, CFA® – TCI Wealth This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent chats with Tony Yu about the important differences between China, Singapore, Taiwan and Vietnam from a cultural, monetary, and planning perspective. They discuss how to adjust to those differences, understand where they may be coming from, and enjoy the rich tapestry of those nations. Tony is the owner of DSG Wealth and Trust Law. He graduated cum laude from UCLA with degrees in Business–Economic, Communications, and Accounting. Tony is fluent in English, Mandarin, Spanish and Taiwanese. Tony was a Trust Attorney at Holland & Knight LLP,  the largest trust law firm in the US and a former clerk at the Los Angeles Probate Court. ​In 2008 and 2012, the Southern California Super Lawyers Magazine recognized Tony Yu as a “Rising Star” in law (top 2.5% of attorneys). Tony is also the 2nd Generation Owner of DSG Insurance, which was founded in 1986 by his father, Castor Yu. Utilizing Tony’s diverse legal, accounting, and financial planning background, DSG specializes in Business Protection, Tax & Business Planning, and Wealth Transfer. Tony can be found here: http://www.dsgtrustlaw.com/ And here: https://www.dsgpcins.com/president/ This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates.If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/.Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent chats about the One Big Beautiful Bill Act (OBBBA) and its impact on estate planning for ultra-high net worth families. He gets into the increased estate tax exemption, tactics for using and managing high exemptions, opportunity zones, and the increases to qualified small business stock exemption, and the SALT cap, among other things. This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent chats with Wallis Tsai about how to avoid the many bad life insurance policies with objective analysis. They discuss how to avoid those bad life insurance policies, war stories of nightmare scenarios, and good use cases for the right insurance. Wallis Tsai is the founder and CEO of AboveBoard Financial. Wallis developed a passion for quantitative analysis (and let’s be honest, Excel spreadsheets) during her 10 year career at Goldman Sachs, first as an investment banker and then as an investor for an elite hedge fund group. At Goldman Sachs, Wallis was a member of a four-person team managing the multi-billion dollar Americas and European financials portfolio. She developed the fund’s perspective on financial regulation, US housing market, banking and capital markets. As an expert in the insurance industry’s inner workings, Wallis often found herself advising friends and colleagues on personal finance matters. She was repeatedly appalled by how often they got terrible advice from the industries that she knew so well and decided to follow her dream to offer financial services the right way. Wallis delights in making wonky financial topics engaging and accessible (like our “truth vs. BS” scale to rate insurance sales lines) and has taught classes on how to avoid insurance rip-offs at Harvard Business School. Wallis enjoys taking in the wonders of New York City with her husband, two kids, and rescue dog. Wallis can be found here: About Us | AboveBoard Financial This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent chats with Evan Unzelman about the many creative uses of charitable remainder trusts. They talk about modifying the trust, selling the income interests, contributing the income interests to new trusts, and using CRTs as IRA beneficiaries. With 20 years of specialized experience with charitable remainder trusts (CRTs), Evan Unzelman is largely regarded as one of the nation’s foremost experts on CRTs. Over the last two decades, he has reviewed thousands of CRTs and worked with tens of thousands of CRT beneficiaries, their families and their advisors on all facets of CRT planning. From up-front design and CRT structure (Standard CRUT, NIMCRUT, CRAT) to complex CRT administration to CRT secondary planning, Evan provides unmatched insight at every stage of the CRT lifecycle. Evan’s experience with CRT secondary planning – sales, gifts, and rollovers of CRT income interests – is particularly deep. Prior to forming CRT Experts, he was President of a charitable planning firm where he helped develop the secondary market for CRT income interests and personally oversaw the successful completion of sale transactions for thousands of CRT beneficiaries across the U.S. Evan is a trusted resource for trust and estate attorneys, CPAs, and financial advisors on all aspects of CRT planning (sales and exchanges of CRT income interests in particular) and structured CRT Experts’ service offering to be complementary to those of most tax, legal and financial advisors. CRT Experts does not manage or custody assets and does not provide tax, legal, financial or insurance advice. Evan is a sought-after speaker (partial list of speaking engagements below) and writes frequently on CRTs for a variety of audiences. His articles have appeared in publications such as Estate Planning, the National Association of Estate Planners & Council’s Journal of Tax & Estate Planning, Taxation of Exempts, Atlanta Bar Association’s The Mortmain, Wealth Strategies Journal and Atlantic Trust’s Trusted Advisor. Born and raised in the Pacific Northwest, Evan graduated from Pacific Lutheran University (summa cum laude) in Tacoma, WA, where he earned degrees in Finance and Economics. Evan can be found here: About | CRT Experts This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent chats with Sasha Young da Silva about estate and tax planning for Americans who have relocated to beautiful Portugal. They talk about the tax challenges of cross an international border, surprises Americans find in the Portuguese system, and how to make the transition. Sasha Young da Silva is a U.S. attorney with a practice focused exclusively on tax and estate planning for American private clients living in Portugal. Born in New Orleans and raised between Aruba and Atlanta, Sasha’s global perspective is shaped by a lifetime of international living, including time in Miami, Chicago, Los Angeles, San Francisco, Seattle, Mexico City, Bogota, Cartagena, Puerto la Cruz, Alexandria, and now Lisbon. She began her legal career at White & Case and McGuireWoods, where she advised on complex project and asset finance transactions, including aircraft leasing, energy sector financing, and major infrastructure projects. She later transitioned to an in-house role at Amazon Prime Video, supporting production and licensing transactions across Latin America and advising on international tax, currency, and regulatory matters. Sasha’s diverse background gives her a unique understanding of the challenges facing globally mobile families. She offers bespoke U.S. tax and estate planning solutions that account for the cross-border realities of American expats, with an emphasis on clarity, compliance, and long-term family security. She holds a Juris Doctor (J.D.) from Northwestern University Pritzker School of Law and a Bachelor of Arts (B.A.) in Political Science from California State University, Northridge. She is licensed to practice law in Florida and Washington. She speaks English, Papiamento, Spanish, and Portuguese and takes her coffee cheio com açúcar. Sasha and her firm can be found here Tax & Estate Planning for Americans in Portugal | Areia Global This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent chats with Nicole Davis, CPA, MBA — founder of Butler-Davis Tax & Accounting and a Forbes Top 200 CPA — about why today’s accountants can (and should) treat traditional compliance work as a choice, not a requirement. Nicole explains how technology, distributed workforces, great processes, and training clients can help accountants (and any other professional) find more time for high-value advisory work. Nicole Davis, CPA, MBA, is the founder/CEO of Butler-Davis Tax & Accounting, BD Payroll, and Groundworx Contractors. A sought-after speaker and creator of “Tax Return Pizza Tracker,” she coaches accountants through The Modern Bookkeeper accelerator and keynotes national conferences on client experience, pricing, and firm culture. Nicole can be found here Nicole Davis, Cpa, Mba And here Nicole Davis, CPA This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent chats with Joel Revill about Private Trust Companies (PTCs). They explain the basics of PTCs and their structures. They explain what families would want to use a PTC and how the structure can solve issues of governance and management of family wealth. Finally, they discuss the unique position of PTCs with crypto assets. Joel serves as CEO of Two Ocean Trust. Prior to co-founding the firm, he was a Portfolio Manager at Citadel, a $63 billion alternative investment manager. Joel began his career in the investment banking group at J.P. Morgan.  Joel chairs the Selection Panel for Wyoming’s Investment Funds Committee, overseeing the state’s $30 billion sovereign funds. Appointed by Governor Mark Gordon, he also serves on the Wyoming Blockchain Select Committee, which has pioneered over 30 laws on blockchain and emerging technologies. Additionally, he is on the Wyoming Stable Token Commission, managing the first state-issued stable token. Joel’s leadership extends to numerous boards for private trust companies and non-profits organizations, including his current role as Investment Committee Chair for the Community Foundation of Jackson Hole. ​He holds bachelor’s degrees in Finance and Japanese Language and Literature from the University of Oregon and studied at Obirin University in Japan. Joel also pursued graduate studies in the Master of Liberal Arts program at Stanford University. This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent talks about what tax planning can happen AFTER the client has already signed the deal to sell a large asset. He talks about the difference between income and estate tax planning. He then discusses terms of the deal, installment method, QSBS, charitable giving, and charitable lead annuity trusts. He closes it out with a discussion of how discounts may still be available on gifts, even after the ink is dry. This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent chats about five key questions relating to tariffs and planning in difficult market conditions. He gives answers to the following questions: 1. What’s the real strategy behind these tariffs—and what is the administration hoping to achieve by imposing them now? 2. How might these tariffs and the market’s reaction affect U.S. consumers and investors in the short term? 3. How do currency exchange rates fit into this picture—and why does it matter if the U.S. dollar strengthens or weakens? 4. How can volatile markets actually create opportunity for strategic estate planning? 5. In times like this, what are the biggest estate planning mistakes people make—and how can they be avoided? His answers cover what the stated motivations for the US tariffs are, how they might effect the markets, currency exchanges, and planning, and how to find silver linings from a planning perspective. This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent chats with T.J. Ryan about important terms to make your trusts better. In this first part of that conversation, they discuss the importance of settlor intent, HIPAA releases and incapacity determinations, determining the character of property of the trust as community property or separate property, holding property in lifetime spendthrift trusts with careful distribution provisions, and using special co-trustees strategically (drug testing anyone?). T.J. is a Senior Partner at the Phoenix law firm of Frazer Ryan Goldberg & Arnold LLP. T.J.’s practice encompasses virtually all aspects of family estates, from estate and business planning, to probate and trust administration, to litigating contested estates – an area in which he has achieved a strong track record for positive results. A Fellow of the prestigious American College of Trust and Estate Counsel (ACTEC), T.J. Ryan focuses his practice on personal and business planning, including estate planning, estate administration, business entity formation, and trust and probate litigation. T.J. can be found here: T.J. Ryan, Trust & Estate Litigation and Estate Planning Attorney This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent chats with Steven Zeiger about why life insurance products are so complex. Steven explains the mechanics of the products and how data can reveal which are best for our clients. Steven also shares his methodology and best practices for comparing life insurance options. Steven Zeiger is a Managing Director of Wealth Management at KB Financial and is a recognized professional in applying prudent investor guidelines to life insurance product selection and portfolio management according to established and proven asset management doctrine. Prior to joining KB Financial, Steven worked for an Austin, Texas firm specializing in Private Placement Life Insurance for ultra high net worth families where he oversaw marketing efforts for the Northeast. After graduating from the State University of New York at Albany School of Business with a BS in Business Administration and concentration in Finance, Steven received his advanced Insurance degree from the Wharton School of Business. His California Insurance License is #0C33107. Steven lives in Chappaqua, NY along with his wife and sons and enjoys travel, tennis, skiing, and ping pong with his family. He is on the Board of the Kidney Cancer Coalition and participates in the MSK Cycle for Survival. He is currently training for next year’s 192-mile Pan Mass Challenge where he will be riding alongside his sister on her 15th annual ride. Steven can be found at [email protected]| onedigital.com & kbfcllc.com This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent chats about how AI can be used in estate planning now. He discusses its current limitations and dangers associated with AI-Emboldened Advisers. He also discusses the future outlook of AI and how advisers can remain relevant. This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

In this Live recording, Brent chats about the state of the tax bills in Washington, DC, an interesting fiduciary liability case involving foreign accounts, how to plan for an uncertain future, and what gifts volatile markets bring for private wealth transfers. This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/ [Transcript of Episode] Good morning. This is the Wealth and Law podcast live. Basically, this is a little bit of an experiment because we haven’t done this before. So you have to forgive me if I have any sort of technical issues here. I’ll do my best. But the intent is to record some of the podcast episodes that I’ll be doing in the future in a live format like this and then to uh hopefully put those up so you could you don’t have to catch them live so you can listen to them during the day or at your leisure whenever you want as separate episodes for the podcast but hopefully we’ll be able to have a little bit of a mix uh so there’s more ways to engage with and listen to the podcast and so this is this is round one of trying to figure out um some way of doing that and basically the podcast is me so if there’s any sort of technical issue or the sound isn’t right or it doesn’t get posted or something doesn’t happen, it’s all me. This is how it gets done. And that also means that I have technological limitations. So if these sorts of things don’t work, it’s also on me. So, you have to hopefully forgive me for any issues that pop up. Just give you like the brief agenda here this morning, and then I’ll jump into it. I’m going to talk about current events, such as they are, current events that relate to sort of private wealth and tax and things like that, not all the current events. We can talk about all the current events at a separate moment over drinks. That would be an appropriate time to do that. Then there’s an interesting case, I think, anyways, an interesting case right now out of the federal district court in Idaho about foreign accounts and particularly about the liability of a fiduciary for a deceased person’s foreign accounts and reporting. And then we’ll talk about some of the market volatility and what that means and some of the things that you could probably do to take advantage of some of the market volatility. And then we’ll hopefully close out by just, I’ll just give you my thoughts on dealing generally with uncertainty, sort of market uncertainties and legal uncertainties. We know right now, for example, that in Congress, they are working on a spending bill to keep the federal government funded. Of course, this happens just periodically, so it’s not really anything new in every single Congress that goes through this same process. I don’t really think that It’s enormous news. They’re always threatening to not fund the government and then cause a shutdown and whichever party happens to be in power is the one trying to fund the government. Whichever party is not in power is the one threatening to shut down the government. I am not seeing a whole lot of indication that they are going to shut down the government either because the Democrats don’t have enough votes to do it or because some of the Democrats will actually fall in line to keep funding the government because it might not be such a great idea for Democrats who are opposed to firing federal employees, for example, to then furlough a bunch of federal employees because they can’t agree to fund the coffers of the government to pay those employees to do their jobs. I just don’t see that really happening. I think the really big ticket Item which has gone very silent in the last week or so is the reconciliation bill that may include both immigration reform and the tax bill. And I say may because there’s been some debate. I’m not a hundred percent certain that in Congress, they, as far as I can tell from the news that I’m reading that they are convinced that you’re going to have both things in one bill. I know that there’s, there’s been some indication that that’s what they wanted to do, but I don’t know that we’ve gotten a final word on that, but let’s just assume that either of the two is going to be true. Okay. They’re either going to, do the tax bill or they’re going to do immigration or both. I mean, both of these are going to be very big horse trading events because even members of the Republican Party are going to have things on their wish list that they want that are priorities for them that are maybe not priorities for other members of the Republican Party. And the Republicans have a very, very thin majority. And so They really are going to have to have everybody in line, which means there probably is going to be a significant amount of negotiating. I’m already seeing the news reports come out of industry groups who are heavily lobbying Congress currently in this reconciliation process to make sure that they get the tax benefits they think they deserve. So all of the big ticket industries in the country, including tech and oil and gas, et cetera, are lobbying. And then I have seen some indication that there’s some negotiating going on as you would expect over like the state and local tax deduction, the SALT deduction. So I think those things are really gonna dominate the news cycle once we get beyond the funding of the federal government, which again, I expect that’s just gonna happen. They’re gonna fund the federal government. There’s not gonna be a shutdown. I’m just not seeing enough of a collective voice advocating for a shutdown to indicate to me that that’s gonna happen, at least from my experience of watching these things play out. tax bill will be interesting and again the the news on the tax bill and the actual details of the tax bill has gone very very quiet in the last few weeks um I don’t think that means they’re doing nothing I think it just means that they’re not sharing there have been a couple of bills introduced to potentially get rid of the federal estate tax but I’m not I’m not convinced that’s a strong likelihood, although I’ve been wrong about these sorts of things in the past, but it doesn’t seem like there’s a huge appetite for that because of the price tag involved and all of the interests trying to get their share of the pot here. It’s a four and a half trillion dollar pot. Do they really want to spend it on getting rid of the estate tax, which is going to be several hundreds of billions of dollars when they can take that money and spend it, so to speak, on something else by just extending the Trump tax changes from the Tax Cuts and Jobs Act in twenty seventeen? That feels like low hanging fruit. And then to negotiate on the edges of anything new, we know that it’s a priority for the White House to have things like no tax on tips. So they’re going to have to find room for that. Another priority of the White House, of course, is to have no tax on Social Security. So they’re going to have to find room in that four and a half trillion for that. And just extending the current Tax Cuts and Jobs Act provisions is very expensive. So It doesn’t seem like there’s a lot of room for them to wiggle such that they would want to spend it on the estate tax with the estate tax exemption so high that it affects very few people. It just feels like a nominal issue, but we’ll see. We’ll see. Maybe they’ll surprise us. My expectation is that the estate tax is going to be extended at the current levels, index for inflation, of course. And we’ll just sort of carry on with what we’re dealing with now, which is technically set to sunset at the end of this year. But I don’t think it will sunset. Okay. There is a, I think there’s a very interesting… case out of Idaho that it’s not necessarily interesting in its result. The result is what I would expect it to be, really. But it’s an interesting illustration of some of the perils that both taxpayers and then their family and the administration of their estate can face when they are owners of foreign accounts so if you have a foreign account as most people know that that or foreign accounts in general it can just be it can be more than one that in the aggregate during the year have a balance of more than ten thousand dollars u.s then you have to report all those accounts on a foreign bank account report or FBAR. And then if you meet other thresholds, you may have to file other forms. There’s the form eight, eighty nine, thirty eight, which is the FATCA disclosure. And there can be a whole host of other things, depending on what’s in that account that you have to file every year. And if you fail to file, then you can be penalized both civilly and criminally. The civil penalties can be quite high. And in some instances, the IRS is very aggressive in going after taxpayers for failing to disclose these accounts properly and timely. In this case, the decedent was in the CIA and of course had been posted abroad and had foreign accounts that were undisclosed and then died. And that liability, what happens is it falls on the shoulders of the executor or there’s a trustee that’s basically administering the assets it falls on the shoulders of the executor or trustee and now that fiduciary basically steps into the shoes of the deceased person and the liabilities of that deceased person and in addition if now the fiduciary has in essence inherited these foreign accounts and the obligation of disclosure of the foreign accounts, that fiduciary also has to start disclosing the foreign accounts. And they may have to go back and try to clean up undisclosed foreign accounts to try to avoid the worst of penalties by either utilizing the IRS streamline procedures, or if they can use the delinquent filing procedures, which are for, if you had a reasonable cause for not filing on time, these disclosure statements. And these disclosures, they’re really, the information that gets penalized is just information. It has really nothing to do with tax, although there can be tax owed, but the thing you’re getting penalized for is not filing an information form. So it can be really harsh, but the fiduciary steps right into that role and they have to take that mantle and then they have to clean up anything that needs to be cleaned up and they have to start complying themselves as if they were the deceased person. And the estate can be held liable for not doing that. And then in this particular case that has come out of Idaho, that’s exactly what has happened. If that fiduciary then has a liability that’s owed to the federal government, they don’t clean it up, but then they distribute the property without paying the federal government first, the fiduciary can be held personally liable for that obligation that wasn’t paid to the federal government. There’s sort of a federal priority statute that says that. And then if that, of course, the fiduciary transfers assets, now say the estate doesn’t have any assets, the transferees or the beneficiaries of the estate themselves can become liable for the debt that wasn’t paid to the federal government. So all the way around, everybody involved can be left holding the bag, especially when the debtor is the federal government. Because in a normal estate administration, there is a process where you can deal with creditor claims. And if a typical creditor doesn’t make a claim on a timely basis, then they may not be able to get paid. With the federal priority statute, that’s not the way it works. The federal government takes the position that you cannot cut them off from a debt that’s owed to them without basically paying them or negotiating it away. So word to the wise, this case is an illustration of the challenge that can arise for an estate or a fiduciary that now is dealing with foreign accounts of someone else, the liabilities and the responsibilities for those foreign accounts do not just vanish if they haven’t been properly dealt with during the lifetime of the deceased person or during the administration of the trust, if it is a trust. So you do have to be kind of careful about that. But that case is relatively recent, but it’s a very good illustration of this issue. It’s kind of a scary one. It comes up from time to time for me. And I wonder about the knowledge or the sort of understanding of some of the executors and trustees in terms of how to deal with these issues and even understanding that the issue exists. So now, now that I’ve told you, I guess, you know, so good or bad. All right. I want to talk a little bit also this morning about the volatility in the market. Of course, markets are down. They basically have erased any gains that we’ve had since the Trump inauguration, which is a very short amount of time. It’s not really a significant amount of time, but the markets have been down. It’s always news when the markets are down, of course, because it’s easy to see red and green numbers on the screen. So it’s very easy to report on. And so it’s everywhere in front of your face. I’m usually not so hyper focused on the day to day activity and ups and downs of the market because it doesn’t really matter. It certainly doesn’t matter for most of my clients, but it can create an opportunity. particularly if you have clients that have positions in some of these companies that are subject to these market swings in a situation like this, where there’s an event happening that is driving the market down, you know, allegedly. I guess nobody really knows what drives the market. Otherwise, we’d all be billionaires. But the Sometimes these events seem to have a correlation to what’s happening in the market and may, in some sense, artificially be driving the market down. And you can see this in both equity markets and in, say, the crypto markets right now, where, say, the threat of tariffs are making enough people apparently uneasy that it’s causing the market to go down or it’s changing sentiments or whatnot, but it’s not really important. The important thing is to see this volatility and kind of the drop in the market, because from a planning perspective, then in the private wealth space, it opens up actually opportunities for doing some good planning at, in essence, a discounted rate. Certainly, you can do grant planning if you have concentrated positions in public companies that are dropping in the market. When the price is low, that’s the right time to do grant planning. And I have some clients in that situation right now where I’m looking at the circumstance in the market thinking, well, maybe we’ll accelerate doing the grant planning that we were going to do say in the next month or two, maybe we’ll push that forward and do it quickly because we’ve got this volatility in the market that we can lean into and take advantage of. In addition, it can be a situation where when you have entities like trusts or say family partnerships that are trying to really grab highly appreciated property to push appreciation across the line. You can kind of use this as a moment to buy those and push that appreciation across the line. And then in some sort of very more exotic transactions where you might be doing something like a private derivative or sort of private option transactions, if you can peg the price of the derivative or you can peg the price of the option to this lower market rate, then you may be able to shift more assets in the future if the markets go up and now you’re paying off that derivative contract, say to a family trust, or you’re paying off that option contract to a family trust, you may be able to pay it off in shares that have appreciated in value. So the volatility is not always bad from a planning perspective. It can create some opportunities. Of course, everything is a risk because you can never guess really properly about what’s going to happen in the future. We just don’t know. when there is some volatility that appears to, in a sort of reasonable best guess, it appears to give you a chance to grab something at a discount and possibly do some planning, it’s oftentimes worth a shot. And GRATs are really great for that because with the GRAT, you, You either win or nothing happens because if the grant quote unquote fails because the asset doesn’t increase in value sufficiently to beat the hurdle rates that you have to beat in the grant, which is typically just like an interest rate that you need to cover in order to shift value from the grant over to family. If you don’t beat that, then what happens is the assets in the grant just come straight back to the grantor and they’re put back in the position that they were originally. Well, That’s a pretty good bet. If you’re just trying to shift pieces of the estate off to family without having to use up any of the exemption that’s available from estate tax and gift tax and GST tax for the grantor of the trust, that’s a pretty good option. You can just bet, put something into the grant, see if it works. And if it does work great, you just shifted something off of their balance sheet without using up any of this exemption and If it didn’t work, they’re just gonna get it back and they’re in the same position that they would have been originally. So it’s sort of no harm, no foul in many cases with those grad transactions. So the volatility really opens up interesting prospects for grad planning in normal circumstances, I’ll say. Again, we don’t know what’s gonna happen in the future. We have no idea what’s gonna happen with the markets and we really don’t even know what’s going to happen with tariffs from day to day, to be perfectly honest. So that’s always the case. And you always have to go into the planning with that understanding. But if you can use techniques that give you an easy out, like a GRAT gives you an easy out, if you don’t get the result that you want, then you might as well take advantage of it because it’s there. And I’m seeing that sort of, type of transaction that that sort of capping type transaction which is really what a grad is you’re trying to cap the value of the balance sheet of the grantor um for clients that are sort of in that like thirty to forty million dollar as a couple thirty forty million dollar range where they’re like they’re a little bit over existing exemptions if inflation helps you out in the next few years then you might you know you might catch up with available exemption, but you might not actually want to use up all of their exemption and making big gifts because then they’ll have no money left, then you have to kind of try to find ways to start nibbling away at the edges on that balance sheet to keep things down and maybe not expose too much to estate tax, if at all. And this, you know, these can be useful ways to kind of try to nibble away at the edges and cap down the balance sheet a bit. So it’s a useful exercise when you have this kind of market volatility to start thinking about who has a balance sheet that fits into this and makes it easy to do the planning. And if a client has or they can purchase publicly traded shares of stock, that’s usually the easiest, especially in the GRAC context. Finally, I want to just talk a little bit about uncertainty in general because we’re dealing with a lot of it or we have been dealing with a lot of it. And one of the challenges of uncertainty and trying to plan for uncertainty, of course, is that you’re making guesses today that are going to manifest themselves in some very concrete way in the future. And your assumptions today could be wrong, obviously. And so in that scenario, what do you do? How do you do planning? Well, I think sometimes you have to kind of take a two-step approach, I’ll say. Step number one being that you do the planning with an eye towards the long-term, first and foremost. So you don’t try to guess too much about the short-term, notwithstanding what I just said about the volatility of the market and using GRATs, but you try not to guess too much Um, about the short term, you try to focus more on the long-term planning, um, using reasonable assumptions. If you, if you have to pick assumptions, then you use, you try to use assumptions that are based on like historic data and not necessarily guessing about the, the vicissitudes of what’s happening currently and the political news and economic news or whatnot. And so that’s sort of the first thing. The second thing is that then you have to try to build into the structure a lot of flexibility where you can get it. And if you can add in the flexibility, then in anticipation of what could happen in the future, even if it’s some flexibility or some mechanism that you’re not gonna use today, and you have no reason to use today, you build in that flexibility in the plan. So for example, I do a lot of planning with Q-tip trusts between married people, because with the Q-tip trust, When one spouse dies, I can put assets into the Q-tip trust. I can use the election for this Q-tip trust to create multiple trusts if I want, which is sometimes called a Clayton transaction. And all of that planning can be done after the fact, after the first spouse dies, for example. uh and it’s retroactive to their date of death but you get up to fifteen months to do it because it gets reported on an estate tax return and with an extension and state tax return can we do up to fifteen months after uh somebody dies so we use that fifteen month period to try to build in the flexibility to pick and choose the planning by using this q-tip trust tool that’s available to us and sometimes we only have the Q-tip trust. Sometimes we don’t even have the Q-tip trust after the first spouse dies. And sometimes it’s a mix of the Q-tip trust and another trust, either called a credit shelter trust or bypass trust that we elect into. And just having that sort of base level flexibility is very, very handy. And if you use it right, it can give you the ability to do retroactive planning after somebody dies. But to get that option, you have to create the terms in the documents that allow you to have that option in the future. So when I’m talking about long term planning, and then sort of thinking about having tools in the future, that’s really what I mean, you pick the tools that you want in the future today, put those into the documents, you pick the tools that have the most amount of flexibility, you put those into the documents, today. And then in the future, when something happens, then you wrestle around in the toolkit, so to speak, and you pick out the one that works the best. In in many instances, if you’re going to have planning, for example, that involves irrevocable trusts, then you want to have flexibility in that irrevocable trust document. by permitting trustees to, for example, do a decanting if that’s needed, a decanting being a distribution from one trust to a second trust with slightly different terms, or you have to have someone like a trust protector who has the power to maybe amend the document, and how much amending power you give them is sort of in the eye of the beholder, and you decide what is the right amount for your clients to do that. But having that flexibility built into the trust structure is important because in the future, there could be circumstances that arise that you didn’t anticipate. And so you don’t necessarily want the whole structure to crumble. You want to be able to adjust and keep all the best parts of it and then get rid of any parts that might be detrimental in the future. And some of these structures, they’re very powerful. in the way that they operate. They can have extremely powerful credit protection features to them that you wouldn’t necessarily want to just get rid of. They can have extremely powerful estate and generation skipping transfer tax planning features to them that you may not want to just get rid of. And they can have very powerful income tax planning optionalities to them that you also may not want to necessarily just give up on. But to have the ability to pick and choose among options in the future, again, you have to build in these tools into the documents today in anticipation of what could happen in the future. So that’s what I’m seeing most of. And frankly, when I’m talking to other practitioners, that’s what I’m hearing from them as well. They’re trying to anticipate the need to make changes in the future because things are always uncertain, of course, and we can’t predict the future, but it just feels like with the threat to increase or decrease, the estate tax or threats to change rules to certain trust planning structures and tax planning structures, which we get in these federal cycles of who happens to be in control. In Washington, DC, you need to be as nimble as possible to make sure that you can adequately cover yourself from a planning perspective and have the option to make changes in the future should it be required. And every client, of course, is different. Every family is different. States do things differently. And so every circumstance has to be really evaluated for its own merits. I don’t really have perfectly good general advice that will apply across the board. You just keep yourself as flexible as you can. And keep flexibility in mind when you’re thinking about how to do the planning, how to create the structures. All right, well, I’m going to leave it there. You’ve tolerated me here now for about thirty minutes, but I appreciate anybody joining here for the live events. We’ll keep trying to do these in live fashion. And, um, and then we’ll post them as separate episodes. As I said, I really appreciate it. Really, really appreciate all the comments and, and constructive criticisms that I get. So, you know, keep them coming, put comments in posts, or you just reach out to me directly. Let me know what you think. Um, and we’ll see you next time. Thanks for joining me. [End of Transcript of Episode]

This is an episode from March 2022, where Brent talks about his history with Ukraine and Russia’s invasion. Although we are now almost three years removed, the content seems as relevant today as it was then. This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent chats about how adding leverage (or debt) to estate planning vehicles can increase the wealth transfer potential. He talks specifically about adding debt in irrevocable grantor trusts, GRATs, and family limited partnerships. This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent chats about how to move a trust’s income tax residence to a State with no income tax. He talks about what trusts can do this and when and why it might make sense. He also explains when the math does not favor that kind of move. This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent chats about the new administration, and news of tax proposals from Republican tax negotiators. He shares his thoughts on tariffs, lower C corporation tax rates, the SALT deduction, the 199A deduction, opportunity zone funds, and estate tax. He also discusses what some of these changes could mean for taxpayers trying to plan. This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent chats about how he’s thinking about using the 2025 Estate Tax exemption of $13.99 million. He discusses getting ulta-high net worth clients to act, the basic planning frameworks and numbers, and benefits of the full picture. This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent chats with Ryan Halvorson about how to make smart moves with equity compensation. They talk about different kinds of equity compensation, from RSUs, stock options, to deferred compensation. They then explain what issues to watch out for and how to make smart decisions from a financial planning perspective. Ryan Halvorson is an advisor at TCI Wealth Advisors. With more than a decade of wealth management experience, he brings determination and passion as an advisor. He provides tailored advice to help individuals make informed decisions about their financial future. Prior to joining TCI, his professional journey included roles at Merrill Lynch, US Trust, US Bank Private Wealth Management and Morgan Stanley.  Beyond the numbers and charts, building relationships with clients is what Ryan enjoys most.  These relationships go beyond transactions and are founded on trust and understanding. Ryan’s goal is to create connections that stand the test of time. He is honored to be a reliable and steady partner with his clients that will last for the next 20-30 years.   Ryan can be found here: Ryan Halvorson, CFP® – TCI Wealth This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent chats with Paul Hood about what the world looks like for buy sell agreements after the US Supreme Court’s decision in Connelly. They discuss how, if at all, the decision changes existing law, what business owners should think about for business succession planning, and where the case leaves us going forward. Paul Hood obtained his undergraduate and law degrees from Louisiana State University and an LL.M. in taxation from Georgetown University Law Center. Paul has taught at the University of New Orleans, Northeastern University, The University of Toledo College of Law and Ohio Northern University Pettit College of Law. Paul has authored or co-authored nine books and over 500 professional articles on estate and tax planning and business valuation. A frequent contributor to Leimberg Information Services since its inception, Paul is a highly sought after speaker and consultant due to his innate ability to see through complexities and explain difficult and even boring subjects in understandable and entertaining language. He minces no words in doing so. Along the way, Paul’s been a father, husband, lawyer, trustee, director, president, partner, trust protector, director of planned giving, expert witness, agent, professor, judge, juror and a defendant, and he uses his experience in these myriad roles to guide others. Paul can be found here About | Paul Hood Services A text of the case can be found here 23-146 Connelly v. United States (06/06/2024) This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent chats with Toni Ann Kruse about what it means from a practical and tax perspective to expatriate from the United States. They explain the difference in residency, covered expatriates, and significant tax considerations. They also talk about some of the day-to-day challenges of leaving the United States. Toni Ann Kruse is a Partner at McDermott Will & Emery who has a broad-based estate and wealth transfer planning practice in New York. She advises ultra-high net worth individuals and families on estate, gift and generation-skipping transfer tax issues, trust and estate administration, state fiduciary income tax planning, and charitable gifting, as well as contested trust and estate matters. She has significant experience working with multinational clients on structuring efficient ways to benefit US persons as well as inbound and outbound planning opportunities. Toni Ann regularly works with family companies, advising on governance and succession issues between generations; drafts and administers complex estate plans; implements leveraged lifetime wealth transfer techniques; and counsels fiduciaries in complex trust and estate administration matters, often involving various asset classes across several jurisdictions. Toni Ann has published articles in publications such as Trusts & Estates Magazine, Bloomberg Tax, Law360, and the New York Law Journal. She regularly speaks at estate planning conferences on various topics and has been quoted in the Wall Street Journal, Forbes, and Reuters as an industry expert. Toni Ann can be found here: Toni Ann Kruse – McDermott Will & Emery This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent chats with Geoff Grenert about how to help client understand complicated ideas as part of their planning. They discuss the challenge of explaining things simply, helping people overcome their own fears, and ultimately helping people make wise decisions. They also talk about their processes for creating and delivering the message their clients need to hear. Geoff, Cypress Strategies founder, has worked with affluent families and businesses since 1997 in the area of legacy planning. He helps his clients crystallize their goals and objectives from a family, business and personal perspective. Together with his support staff and the clients advisors he creates a synergy of talent, education, and resources; providing a dynamic team approach in creating and implementing innovative and efficient planning solutions. Geoff brings years of experience in the design and acquisition of large life insurance policies. Because of his knowledge, trust offices, accounting firms, and tax attorneys seek his advice. This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent explains some of the challenges of planning when there is a non-US citizen spouse. He dives into the estate tax marital deduction, the gift tax marital deduction, Form 3520, income tax recognition events, and expatriation. He also explains how these issues arise at various generational levels of a family. This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent chats with Matt Hochstetler about the basics of irrevocable life insurance trusts (ILITs). They explain what these trusts are, why they are useful, Crummey provisions, and creative planning with life insurance. Matt Hochstetler is a trusts-and-estates attorney practicing in Naples, Florida and Canton, Ohio. His practice serves wealthy families, family offices, and private trust companies across the United States.  Matt counsels clients on estate planning and administration as well as matters concerning the structure and operation of family offices and private trust companies. Matt is an ACTEC Fellow and earned his LLM from the University of Miami Heckerling Graduate Program in Estate Planning, where he was the highest-ranking student in multiple classes.  He received his Juris Doctor magna cum laude from the University of Toledo College of Law. This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent chats about how to think about the US elections, reminds you the CTA beneficial owner reports are due by December 31, 2024, suggests planning based on the laws as they are not as we wish they would be, and spotting important red flags when there are non-Americans in the family tree. This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/

Brent chats about the basics of Remainder Purchase Marital Trusts (RPMTs). He explains how they work within the gift tax marital deduction rules. Then he compares them to QTIP Trusts and IDGTs (see our prior episodes about those). Finally, Brent walks through the mechanics of RPMTs and how they can be effective wealth transfer tools. This material is for informational purposes only. The views expressed are those of the speaker as of the date noted and not necessarily of the speaker’s firm or its affiliates. If you are enjoying the podcast please SUBSCRIBE and leave a REVIEW, and if you want to learn more about Brent go to https://wealthandlaw.com/team/. Legal Disclaimer: https://wealthandlaw.com/legal-disclaimer/