We help accelerate estate planning objectives.
Some of our clients are just starting their estate planning. Most of our clients are embarking on the biggest events or decisions in their lives. From the sale of their businesses to the transfer of significant wealth, Accelerant supports our clients through proactive and thoughtful solutions borne from experience.
You can expect our relationship to grow with your changing circumstances; seeing each facet of your plan to completion.
Our expertise and focus includes:
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Accelerant attorneys have cultivated a unique expertise successfully planning for private equity, venture capital and hedge fund principals. The Internal Revenue Code imposes special valuation rules on planning with fund interests, including carried interests, that can result in draconian gift tax implications. Our attorneys are experts in navigating these intricate rules to avoid unintended tax consequences, including planning to meet the so-called “vertical slice” safe harbor, as well as more nuanced methods of transferring the economics associated with fund interests through private derivative contracts. Each planning technique requires careful structuring and a command of some of the most complex sections of the Internal Revenue Code. Accelerant’s proactive approach to fund planning allows our attorneys to work closely with each fund principal to determine which technique is most appropriate given their fund’s unique structure and/or the principal’s specific planning objectives.
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Accelerant attorneys have represented owners of professional sports franchises in all major professional sports leagues (MLB, NBA, NHL and NFL), providing strategic advice on acquiring and transferring their ownership interests to trusts. Our attorneys are well versed in the nuances of owning a professional sports franchise within a trust structure, and work with the various leagues to ensure that the trusts created by our clients currently meet, or can be adjusted to meet, any league requirements for their owners. Our attorneys are focused on creating structures that permit the ownership interests in these sports franchises to stay in families for generations, while minimizing and even eliminating gift, estate and generation skipping transfer taxes. In addition, Accelerant attorneys have worked with professional sports leagues to obtain league approval for trustees, including private trust companies created by our clients.
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Accelerant attorneys are versed in nuanced and creative ways to plan with Qualified Small Business Stock (“QSBS”) for both income and transfer tax purposes. QSBS treatment applies to shares of a U.S. C corporation that had less than $50 million of assets at the time of investment. If shares are held for the required period of time, and meet the other qualifying conditions, it is possible for a shareholder to avoid federal (and in some cases, state) taxes up to the greater of (i) ten times their basis in the stock or (ii) ten million dollars. What’s more, it may be possible to multiply this income tax exclusion across multiple taxpayers, resulting in significant income tax savings. This type of planning can be exceptionally complicated, and poor planning may result in a complete loss of QSBS eligibility. Our attorneys have a deep understanding of the federal and state tax issues that arise in pre-liquidity event planning with QSBS and have advised countless clients in successfully transferring QSBS stock outside of their taxable estates for estate tax purposes while at the same time assisting them in maximizing their income tax savings through trust structures.
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Accelerant attorneys have cultivated a niche expertise in establishing and administering private trust companies. Ultra high net worth families often seek to create perpetual trust structures to ensure wealth preservation across multiple generations. An often overlooked component of this planning is the need to ensure that control of assets held in these trust structures remains in the hands of the families. Accelerant attorneys are attuned to the need to holistically advise ultra-high net worth clients in not only saving transfer taxes by funding dynastic trust structures, but in architecting a permanent solution for a family’s fiduciary needs. Our attorneys have assisted dozens of ultra high net worth families in establishing both licensed and unlicensed private trust companies to serve as family fiduciaries.
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Accelerant attorneys represent executive officers and top officials of numerous public companies, including several Fortune 500 companies. Careful navigation of the tax code and SEC rules and regulations is required when planning for these corporate insiders. Accelerant attorneys regularly coordinate with inside and outside corporate counsel to navigate SEC reporting requirements, avoid unintentional disgorgement under the short-swing profit rule and manage pre-merger notifications under the Hart-Scott-Rodino Act.
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With its offices in Washington D.C. and New York City, Accelerant attorneys are often called upon by high profile entrepreneurs, political figures and celebrity clients to structure and manage their privacy concerns. Our attorneys have first-hand experience assisting lawmakers and public officials with avoiding the appearance of financial conflict and impropriety by placing assets in blind trust structures. Our attorneys are also deeply knowledgeable with planning with multi-tier entity and privacy trust structures to keep a family’s wealth private and out of the spotlight. Accelerant attorneys act with the utmost discretion and will work with clients’ advisor teams and family offices to find the right structure to maximize privacy.
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