Helping clients minimize their tax obligation through innovative planning techniques is a primary objective of Holland & Knight's Private Wealth Services Team. With that aim in mind, members of the team represented a multigenerational family business to reduce its tax liability by more than $200 million when it sold one of its business units to a Fortune 100 international company.
Our team has served as trust advisor to the family business, as well as personal advisor to its top management, for more than 30 years. When our client first engaged in negotiations to sell one of its business units, our team members acted quickly to both negotiate the transaction and also to implement various wealth transfer techniques to reduce the amount of transfer taxes that would be assessed against family members following the sale. Such techniques included the use of a rolling GRAT program that permitted only minimal gift taxes to be assessed on more than 60 percent of the transaction value that was transferred to the next generation. In addition, the creation of new GRATs shifted significant additional amounts of appreciation on a tax-free basis. Likewise, to minimize tax obligations for family members that lived in states that impose state income taxes, our team created Delaware asset protection trusts to avoid full state income taxes on the transaction.
The sales transaction, valued at nearly $1 billion, was a complex deal that involved 12,000 titled pieces of tangible property and more than 190 real estate leases throughout the United States and Canada.
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