THE CHANGING WORLD OF ESTATE PLANNING A World of Uncertainty and Opportunity Where Have We Been? Where Are We Going? “Predictions are difficult – especially

THE CHANGING WORLD OF ESTATE PLANNING

A World of Uncertainty and OpportunityWhere Have We Been? Where Are We Going?

“Predictions are difficult – especially about the future” Yogi Berra

A. Stephen McDaniel

Wyatt Tarrant & Combs LLP

A BRIEF HISTORY OF TIME

Trusts Date Back A Few Thousand Years To Ancient Egypt

The Will/Trust World As We Know It Appeared In The 8th Century – English Clergy Began Acting As Executors And Trustees

The First Wills Were Nuncupative Lots of Contests In Terrorem Clauses Appeared

A BRIEF HISTORY OF TIME

Advisors Began Calling Themselves “Lawyers” In The 12th Or 13th Century Few Had Offices Most Practiced Out Of Bars Or Pubs

Early Wills Were Interesting – “Lex Testamentaria” (1590) – Early Text Girls 12 Could Make a Will Boys Had To Be 14 (Immature Even Then) An “Old Man” Who Forgets His Name Cannot Make

Will

A BRIEF HISTORY Continued

Attorneys Established The First Trust Companies In The U.S. And England Many Became Wealthy Managing Estates

Corporate Trusts First Appeared In The Early 1800’s – Farmers Fire Insurance And Loan Company Of New York Was One Of the First

1906 - Congress Enacted Laws To Allow Banks To Be Trustees

By 1920 Over 1300 Banks Offered Trust Services

A BRIEF HISTORYContinued

By 1980 Over 4,000 Banks Offered Trust Services & Controlled The Business Trust Assets Jumped To Over One Trillion Dollars

Today Bank Trust Companies Have Less Than Half of the Trust Business And The Numbers Are Falling! Private Trust Companies Are Now The Rage

Wyoming Private Trust Companies I Found 2,907 Non Bank Trust Companies On The

Internet

FEDERAL ESTATE TAXHow Has it Changed?

A Brief History Of The Law #1Even Before I Was Born: Egyptians (700 B.C.), Romans & Greeks Tax Estates1798: First Federal Death Tax Is Passed To Pay For The Revolution

Taxed Inheritances of Over $50It Is Repealed In 1802

1862: The Death Tax Reappears To Pay For The Civil War

It Is Repealed In 1870


A Brief History Of The Law #2

1898: The Estate Tax Reappears, This Time To Pay For The Spanish American War

Is It Proper “To Stand By The Grave Side Of A Dead Father And Collect Tax” Senator Allen

The Tax Is Repealed In 1902

But Factors That Existed Around The Turn Of The Century Caused The Debate To Continue

Jekyll Island


A Brief History of the Law #3• 1916: First Estate Tax - $50,000 Exclusion• 1924: First Gift Tax - $3,000 Exclusion• 1948: Marital Deduction: ½ of the estate

• Maximum Rate 77%

• 1976: Increased Exclusion from $60,000 to $175,625 (’81)

• 1981: Increased Exclusion to $600,000 (’87) and Gift Tax Exclusion to $10,000

• Unlimited Marital Deduction


A Brief History of the Law #4• 1997: Taxpayer Relief Act Call For Increase In

Exclusion To $1 Million• 2000: The Battle For Repeal Heats Up

• Tractor At the White House

• 2001: Everything Is Changed:• Welcome To The State Of Confusion

• Ten Years Of Uncertainty• Ten Years Of Change – What Year You Die

Matters


A Brief History of the Law #5• 2010: The Sky Falls. No Tax But….• How Did That Happen?

• Blanch Lincoln & John Kyle Refused To Vote For a $3.5 Million Exemption

• The Sky Falls: No Death Tax• The “Winners”: At Least 6 of Them

• Dan Duncan (Intergy) - $ 9 Billion

• George Steinbrenner (Yankees) - $1.1 Billion

FEDERAL ESTATE TAX EXEMPTION

1975 - $60,000

1987 - $600,000

2002 - $1,000,000

2005 - $1,500,000

2006 - $2,000,000

2009 - $3,500,000

2010 – NO TAX

2011 - $5,000,000

2014 - $5,340,000

11

ESTATE TAX STATISTICS

• 1976: • 139,000 Estates Subject To Tax• 7 ½% Of All Estates Subject To Tax

• 1996:• 32,000 Taxable Estates• Less Than 2% Subject To Tax• $17 Billion In Revenue

• 2000: • 52,000 Taxable Estates• $24.4 Billion In Revenue

• 2012: (Revenue Was From 2011 Deaths)• 3,738Taxable Estates• Less then 1/4% Subject To Tax• $ 8.5 Billion In Revenue

ESTATE TAX REVENUE

Year

1995

2000

2005

2010

2012

Tax (000,000)

$14.3

$24.4

$21.7

$13.2

$ 8.5

Taxable Returns

36,58852,00020,250 6,711

3,738

ESTATE TAX REVENUE 2012

Year

Under $5M

$ 5M to 10M

$ 10M to 20M

Over $20M

Total

Taxable Returns

237

999

502

405

3,738

Tax (Billions)

$ .1

$ 1.2

$ 1.9

$ 5.3

$ 8.5

WHERE DO WE GO FROM HERE?

• Obama Proposal – It Is Not Over Until It Is Over!

As We Move toward the next election There is More to Discuss

• Fiscal year “Green book” Proposals 2014

• Reinstate the $3.5 Million exemption in 2018

• Move th3 top Tax rate to 45%

• No indexing

• Retain Portability

• No Clawback


• Fiscal year “Green book” Proposals 2014 Continued

• Require GRATS to Run For At Least 10 Years

• Limit GRATS to Run for life plus 10 years

• Killing the 99 year Grat

• Limit GST Exemptions to 90 Years

• Require Basis Consistency

• Limit Crummey Withdrawal Rights to $50,000 a Year

• Strangely, the provisions to Reduce Discounting on Family Entities is gone!


• Republican Proposal – They Have Not Given Up!• Abolish the Death Tax


Lobby Money Is The King! Millions Went Into The 2012 & 2014 Elections Millions More will go into the 2016 Elections

Tax Foundation Survey (2009) Estate Tax Is The “Most Unfair Tax” 2/3 Of The Population Are For Repeal

Possible Results – It Is Not Over! The Fight Will Continue To Repeal The Death Tax If Repeal Is Not An Option The Tax Rate Is The Battle

Field

STATE INHERITANCE TAX

Under Prior Law States Received A Part Of The Federal Estate Tax – State Death Tax Credit - 6% To 16% Of The Federal Share Of The Tax

Since 2005 The Credit Is Gone – Along With $5 Billion To The States

20 States (more or less) Have Decoupled From The Federal Law or Have Their Own State Inheritance Tax Do You Know Which States?

DEATH TAX

So What Does All Of This Mean To You?

DOCUMENTS MUST BE FLEXIBLE

What If The Federal Exemption Changes Again?

What If The Federal Estate Tax Is Repealed?

What If The State Changes The Inheritance Tax Law?

What If Your Assets – Or Values – Change?

What If You Are No Longer Capable Because Of Illness Or Accident To Change Your Plan?

Blowing in the Wind We Are In The Midst Of The Most Radical Changes In

The Estate Planning Profession Since The Federal Estate Tax Was Reinstated For The 4th Time In 1916

Death Taxes No Longer Drive The Train

In 2014 Fewer Than 4,000 Estates Will Be Subject To Death Tax

That Is Less Than 1/2 Of 1 % Of Those Who Die

A CHANGING WORLD

Previous Tax Tools Are Turned Upside Down Will We Argue For Higher Values To Increase

Basis? Will We Reverse The “Defective “ Trust Concept?

Remember The Old Clifford Trusts? Will Marital Deduction Planning Be More

Complex? You Might Want To Actually Leave Assets In

The Estate Of The Surviving Spouse To Increase Basis At The 2nd Death

A CHANGING WORLD

American Society has changed Married Couples 1950: 78%

2010: 48% Married with Children 1950: 43%

2010: 20% By age 85 Women outnumber men by 4 to 1 47% of American families support a minor or adult

child or an elderly parent 15% support both

A CHANGING WORLD

49 million

79 million

41 million

71 million

23 million

• Silent Generation• Baby Boomers• Gen X• Gen Y• Gen Z

MY TOP TEN (More or Less)THINGS YOU NEED TO CONSIDER

WINDSOR v. U.S. Doc # 12-2335-cv (10-12)

Edie & Thea Start Committed Relationship In 1962 1993 Registered As Domestic Partners – New York Married In Canada In 2011

Thea Died Edie Filed Estate Tax Return – Claimed Marital Deduction IRS Says No – Cites Defense Of Marriage Act District Court Agreed With Edie DOMA Unconstitutional Ct Of Appeals Agreed

Supreme Court Rules The Federal Government Is Prohibited From Placing Any Classification On

The Recognition Of Marriages – This Is A State Issue, And Must Be Left To The States

Deinlein v. U.S. 114 AFTR 2d 2014-5390(DC KY) 7/23/14

Taxpayer Owes The IRS Tax Liens Filed

Mother Dies Taxpayer Disclaims The Inheritance Tax Court Holds That The lien Attaches to the interest

notwithstanding the Disclaimer Case Follows Drye 528 US 49 (1999)

FAILURE TO TIMELY FILE 706 TO ELECT PORTABILITY

Rev Proc 2014-18 Provides An Extension To Estates To Elect Portability For Decedents Who Died In 2011,1012 And 2013 Who Did Not Timely File A Federal Estate Tax Return It Applies To Estates Too Small To Require The Filing

Of A Return Requires Filing By December 31, 2014

PLR 201421002 May Offer Help To Those Who Fail To Meet The 12-31 Deadline

ESTATE TAX UPDATE INSURANCE

Remember Rev Rul 2009-13 Outlined Income Tax Consequences Of

The Sale Or Cancellation of An Insurance Policy Did Anyone Care?

The IRS Did! Fujishima Turner Perez Chambers

ESTATE TAX UPDATE LIFE INSURANCE

Brown v. Comm’r (7th Cir 9-11-12)

1982 Brown Purchases NW Mutual Policy

$1,837 Level Premium - $100,000 DB

1987 CVs Used To Pay Premiums

2004 Dividends Used to Pay Premiums & Loans

2005 Loans Equal Cash Values – Policy Terminated By Company

1099: $29,093 Taxable

Court Agrees!

ESTATE TAX UPDATE LIFE INSURANCE

White v. Comm’r, T.C. Summary Opinion 2012-108 (2012)

1992 White Works for Company

Company Offers Insurance through payroll deductions

White pays $22,000 over years

White changes jobs & stops paying

Policy lapses in 2008

1099: $3,000 Taxable

Court Agrees!

ANY TECHNIQUES NEW OR HOT?

NOT MUCH – BUT….

THINGS TO THINK ABOUT

Swap High Basis Assets Held In Grantor Trusts For Low Basis Assets

Get Rid Of Discount Entities – Get More Basis

Give Beneficiaries A General Power Of Appointment

Turn Your Poorer Ancestor Into An Asset Gift Low Basis Assets Into Trust For Parent

Consider A GRAT For The Poorer Parent

Give The Parent A General Power Of Appointment

Parent Dies, Basis Is Stepped Up, Assets Pass To Grandchildren – Sooner Rather Than Later

DEATH TAX AND ASSET PROTECTION

THE FAMILY GIFT TRUST

ALMOST TO GOOD TO BE TRUE

FAMILY GIFT TRUST

Husband Creates Trust For Wife (And Children) For Life Of Wife Maximum Gift $5.34 Million Spouse Receives Income/Principal – Support In Accustomed

Standard Of Living Trust Is Protected From Claims Of Creditors, Future Spouses &

Death Tax At Death Of Spouse

Trust Can Then Be Held For Children For Life & Pass To Grandchildren

Same Asset and Death Tax Protection

No Gift or Death Tax – Ever – Regardless Of Value!

No Probate - Ever

GRANTOR RETAINED ANNUITY TRUSTS MECHANICS OF CREATION/CONCEPT

Assets to Trust

Annuity to Grantor

Family

Remainder for Family

Grantor

GRATS REVISITED

We Obsess Over Short Term GRATS The Walton’s Moved $XXX Using 2 Year Trusts

IRS Rate For November Is 2.2% A 15% Jump Each Year For 2 Years On $1 Million $270,000 Tax Free To Kids

Why Not Go Long? 10 Years Ten Year GRAT $1 Million Assume a 6 % Return over 10 Years $300,000 At End Of The Term

GRATS REVISITED

Assume An IRS 7520 Rate Of 2.2%

Why Not Go REAL Long?

99 Year Zero GRAT !!

$1 Million - $ 24,886 Per Year – Zero Grat

Ten Years From Now the Grantor Dies

The Trust Still has $1 million In Principal

• The 7520 Rate Is Higher – 5%

What Happens?

• The value In the estate is $491,555

• 20.2036-1(c)(2)(iv)(ii)

GRATS REVISITED

• A Grat Is An Annuity• Per Section 20.2036-1(c)(2)(iv)(ii) The Value using the

7520 Rate At Death Is The Amount of Corpus Necessary to yield the annual pay out

• Look At the Amount Included! 2.0% $ 772,000 4.0% $ 603,000

GRATS REVISITED

The Term Is Important

Even A 50 Year GRAT May Not Work

It Is a “Math” Thing

Obama Proposal Limits to Life expectancy plus 10 Years

31 Years for a 60 year old

You have To Run The numbers

Must Address Payment Of The Tax – Not From The GRAT

At Death Might The Trustee And The Child Who Inherits Acknowledge A Merger Of The Annuity Interest And The Remainder Interest And Terminate the trust?

If So..”Poof” It Ends

Might The Grantor Buy Out The Annuity Interest During Life And End It Leaving The Balance With The Child?

CHARITABLE LEAD TRUST

ASSETS

INCOME FOR TERM OF

YEARS

THEN TO BENEFICIARY

CHARITY


Grantor Transfers Assets to Trust

Income (Fixed Amount or Percent) Is Paid to Charity for Term of Years

Grantor Receives Charitable Deduction

Gift to Family at End of Charitable Term Is Discounted

Remember – 65% of American households give to charity - $298 Billion in 2011

161,000 Donor Advised funds in US


Grantor Gives $50,000 a Year To Charity

Grantor Transfers $1 million to 20 Year Trust Remainder to Children Trust Pays $56,530 Per Year To Charity Zero Gift

Assume a 6% Return Over 20 Years

$1,127,000 Goes To Kids 20 Years From Now

Grantor Receives $ 1 Million Charitable Deduction

THE FUTURE OF ESTATE PLANNINGIt Is NOT About Death Taxes!

• It Is Not About Taxes!

• It Is About Leaving A Positive Legacy For Heirs

• It Does Not Start With Things

• It Starts With People

• Protecting And Preserving Family Wealth Is The New Goal

IS ESTATE PLANNING DEAD?

• Just The Baby Boomers Will give us enough work for years

• Lots of Dead People. Lots of Estates to administer

• 2.5 million will die in 2014

• Up from 1.7 million in l960

• 2020: 2.9

• 2030: 3.3

• 2040: 3.8

I SPENT A LIFETIME CREATING AN ESTATE

HOW DO I PROTECT IT FOR THE CHILDREN & GRANDCHILDREN?

HIPAA PRIVACY LAW

Problem: Medical Providers Can Be Reluctant To Release Medical Information On A Child Even To Parents Once The Child Is 18.

Solution: Adult Children Should Sign Medical Power Of Attorney Naming Their Parents.

Problem: Out Of Town Without The Kids?

HOW TO BLOW AN INHERITANCE

35% Wish to protect the heirs from themselves – mismanaging the inheritance Wealth Counsel Industry survey

Lost inheritances (published 3-7-13 in WSJ) 70% of inherited wealth of affluent residents gone by end of 2nd

generation 90% by end of 3rd generation

MAJOR TRENDS

Estate Planning Is For The Living, Not The Dead

I Kill Off Most Clients In the First 30 Minutes Of The Meeting. Why Are They Uncomfortable?

Primary Goal Of Most Clients

Pass Wealth Free Of Tax – NOPE!

Protect The Wealth Of The Family – Yes!

CLIENT GOALS & ATTITUDES ARE CHANGING

Clients Want Satisfying Careers For Children

Children Supporting Themselves Financial Success Is A Low Priority Asset Protection Is High Priority

“I Want My Children To Have Enough To Be All They Can Be…..But Not Be Nothing”

“I Want My Children To Have Enough To Do All They Can Do…..But Not Do Nothing”

CLIENT ATTITUDES - - THE IMPLICATIONS

Greater Use Of Trusts – It Is Not Just Taxes!

Changes In Trustee Roles

Increased Complexity In Structure Of Trusts – Not Just Health, Support & Education

Please Define

Support In Her Accustomed Manner Of Living

Support In Reasonable Comfort

Purpose Clauses Are Important

LITIGATION ISSUES Estate – Will Contests – Are Up Substantially

Bad Document

Dysfunctional family- Greed

Incompetent fiduciaries

Good Estate Planning Includes Making It Difficult For Family To Fight

Contest Provisions – In Terrorem Clauses Required Mediation

LITIGATION ISSUES The Mother Of Probate Law Revisited

89 Year Old Marries Innocent 26 Year Old Marriage Lasts 14 Months Husband Gifts Wife $6 Million Husband Dies 0 $1.6 Billon Estate Wife and Son Go to War Wife File Bankruptcy. Court Gives Her $474 million –

Later Reduced to $90 million Wife Dies Of Overdose Who Is The Daddy? Marshall Case Gets To U.S. Supreme Court Son Dies – But The Fight Continues

LITIGATION ISSUES

The Strange Case Of Brooke Astor

Dies In 2005 At Age 105 Changes Estate Plan in 2004 Son – Age 85 - Indicted and Tried for Fraud and Larceny 19 Weeks Of Trial Found Guilty on 14 Counts Gave Himself a $1M Raise Using Power Of Attorney Sold Art For $10M And Paid Himself $2M Attorney For Ms Astor Indicted and Tried Both Convicted And Likely Going To Jail

YOUR CLIENTS – AN EXPLOSION OF WEALTH

American households have a total Wealth of $66 Trillion Most is owned by the top 20% Americans over 65 have a net worth 47 times the net

worth of those under 35 Are You counting on an inheritance?

Count Again We are living longer It is expensive

AN AGING POPULATION –OUR BIGGEST CHALLENGE

In 2010 There Were More People 65 And Over Than 5 And Under

Those Older than 85 -fastest growing demographic group

3.9 Million live with children

Dementia Treatment Direct Cost To Famlies: $109 Billion In 2012

Average Family spends $41 to $56,000 a year Expected To Double in 30 years

Alzheimer’s Is A Greater Threat Than Cancer Cancer Cost only $77 billion In Direct Cost to famlies

AN AGING POPULATION - OUR CHALLENGE

1985: 1 In 8 Are Over 65

2011: 1 In 6 Are Over 65

3.6 Million New Recipients In 2011

Those Over 100

1990: 37,000

2011: 100,000 plus

From 1990 To 2020 The Average Age Of The Population Will Go From 33 To 42

What Are The Fears Of The Elderly?

AN AGING POPULATION – OUR BIGGEST CHALLENGE

76 Million Baby Boomers (1946-60)

Turning 65 This Year

10,000 A Day

42 Million Are Over 50

Between Now and 2025 Those 65 Over Will Increase 60%

They Are 26% Of the Population

Over The Next 10 Years 30 Million Will Retire

They Are Going To Retire With 20 to 30 Years To Live

AN AGING POPULATION –OUR BIGGEST CHALLENGE

• When Are You No Longer Competent?– Time Test– Animal Test– Thing Test– Count Test

• How Do You Know?• Who Says You Are Incompetent?• Who Manages Your Assets?

• Durable Power Of Attorney

• Who Makes Medical Decisions?• Health Care Power Of Attorney• Living Will

AN AGING POPULATION OPPORTUNITIES

Retirement Funds

Long Term Care

Medical Needs

Disability Needs

Education Needs

THE TIMES THEY ARE A-CHANGING

Think legacy Planning Think Litigation 14 million Legal Aliens Don’t forget Business continuation

87% of Business owners have no written exit plan 47% never intend to retire

Unmarried Partners Are the Norm 8 million opposite sex households 1 million same sex households

Baby Boomer divorces are skyrocketing 66% are initiated by women

Widowers are 10 time more likely to remarry than Widows

SO WHAT DO WE LEARN?

The Tax Law Changed But Your Estate Plan Did Not Your Assets Changed But Your Estate Plan Did Not If We Do Not Die, We Will Get Old?

Will We Be Competent During Our Last Years? Who Will Manage Our Finances?

Documents Must Be flexible What Year Do You Plan To Die? What Will The Law Be? What Will Your Estate Be Worth?

Those Who Fail To Plan, Plan To Fail

CHANGES IN THE TAX LAW

Will prepared in 1999

Client’s Estate: $4 Million – Then & Now

Client wants the Maximum that can pass tax free to go to children of first wife ($650,000 in 2001)

Client dies in 2014

Kids get $4 million – Wife Zero

The Fight Starts! Lawyers Win

THE LAW CHANGED MY WILL!

CHANGES IN THE TAX LAW

THE LAW CHANGED MY WILL!

Will prepared in 2003

Client’s Estate: $4 Million

Client wants the Maximum that can pass GST tax free to go to Grandchildren ($1 Million in 2003)

Balance To Daughters

Client dies in 2014

Estate Is Now $5 Million

Grandchildren get $5 Million

Daughters Split Nothing

THE CHANGING WORLD OF ESTATE

A. Stephen McDaniel

Wyatt Tarrant & Combs LLP

66

NOW FOR 5 MINUTES OF FUN!IF WE HAVE TIME . . .

A BRIEF HISTORYThink About The World

1946 – First Electronic Computer - ENIAC 1947 – Transistor Is Invented 1954 – Firs Transistor Radio & RCA Color TV Hits The Market

1956 First Wireless Remote 1958 – BOA Introduces “Visa”

Consumer Debt Surges 1965 – Fred Smith Gets A “C” 1965 – Gordon Moore (Intel) Predicts Processor Speed Will Double Every 2

Years 1971 – Intel 4004 Processor 10,000 Instructions A Second 2006 – Intel Processor Executes 20 Billion A Second 2008 – IBM Roadrunner 1 Trillion A Second 2011 – Fitijsu 10 Trillion A Second


1969 – Wal-Mart Is Incorporated

1970 – One Sq. Inch Of Hard Drive .9 Megabytes

• 2012 – Segate Introduces Hard Drive with 1 Terabit per Sq. Inch

1970 Texas Instruments TI30 – The Slide Rule Is Dead

1971 – FedEx Incorporated First Answering Machine “Phone Mate 400” Intel 4040 Processor executes 10,000 instructions per second

• Processors Now Easily Execute Billions a Second

1973 – Motorola Introduces Cell Phone 1983 - Cell Phone Hits Market 12”, 2 Lbs, $3,995


1977 Apple Two Atari 2600 JVC Introduces the VCR

1979 – Walkman Introduced 1981 – IBM PC 1984 – FedEx Introduces “Zap Mail” 1988 – Fert & Grunberg Develop Process

Results in Nobel in 95 Results in IPod in 2001

1989 – Berlin Wall Comes Down 1990 – Kodak Introduces Digital Camera 1991 – First Web Sites Appear


1995 – The Dow is at 4,000! NetScape Goes Public First DVD Hits Market GPS Available To Public E-Bay - First Sale Is Broken Laser Pointer Google - Searches Per Day Exceed 400 Million

• 2011 – 4 Billion Ticket Master Sells First On line Ticket China Explodes

• US Skilled Worker $4,000 Per Month• China Skilled Worker $150 Per Month


1999 – the Blackberry Arrives

2001 - Apple iPOD Hits Market

2007 – Dow Hits 14,000 Apple introduces the iphone

2008 – Lehman Brothers files Bankruptcy Fed Reserve Loans AIG $85 Billion Dow Ends Year At 9,000 First Baby Boomers Begin To Collect SS


2009 – More New Cars Sold In China Than US

2010 – Social Security Payments Exceed Revenue Projections Had Said 2016 24% Of Home Mortgages Under Water

2011 Apple Introduces The iPad IBM’s Watson Beats Jennings & Rutter

2012 – Nothing Happened Worth Talking About Fox News Was Wrong The World Did Not End In December Congress Did Nothing Of Value


Now, Why Do You Think That You, Your Office Or Company Can Do Business The Same Way You Did In 1994, 2004 or Even 2010?

The World Has Changed! The Day a Client Can Go on His Computer And Prepare

His Own Estate Planning Documents Is Here Change, Or You Are History

I’M OUT OF HERE

A. STEPHEN MCDANIEL

Senior Attorney – Wyatt Tarrant & Combs LLP 200 Plus Attorneys – 27 Estate Attorneys Memphis Attorneys:

• 5 Certified Estate Planning Specialists (7 In Memphis)• 2 CPA’s• 1 LLM in Tax

Former Attorney With IRS Estate & Gift Tax Division UM Law School Adjunct Professor

Estate Planning, Trust Law, Estate Tax, Insurance Law Named Twice by Worth Magazine as top 100 Estate Planning Attorney In U.S. Past President of National Association of Estate Planners

200 Councils and 20,000 members Past President of Estate law Specialist Board

Administers ABA approved Board Certification of Estate Planning Attorneys