The recent Supreme Court decision in Connelly v. United States has changed the tax treatment of life insurance proceeds under entity purchase—stock redemption agreements when determining a company's value for federal estate tax purposes. Connelly’s estate paid nearly $900K in additional estate taxes, plus legal fees. Please join us as we discuss the complications of this decision and evaluate and expand on an alternative solution.
Learning Objectives
- Upon completion of this course, you'll be able to:
- Understand the role of Buy-Sell Agreement and Required Elements of a Buy-Sell Agreement
- Discuss No. 23-146 Connelly v. United States (decided June 6, 2024)
- Learn about the alternative Structure – Cross-Purchase Agreement and the Multiple-Policy Solution for Partners
Major Topics
- Role of Buy-Sell Agreement and Required Elements of a Buy-Sell Agreement
- No. 23-146 Connelly v. United States (decided June 6, 2024)
- Contrast with Prior Precedent
- Estate of Blount v. Commissioner, 428 F.3d 1338 (11th Cir. 2005)
- Alternative Structure – Cross-Purchase Agreement and the Multiple-Policy Solution for Partners
