Report No. 15 (Thu. 1/17 cont.)
As we have done in January for the last eleven years, and again with the
permission of the University of Miami School of Law Center for Continuing
Legal Education, we will be posting daily Reports to this list containing
highlights of the proceedings of the 42nd Annual Philip E. Heckerling
Institute on Estate Planning that is being held January 14-18, 2008 at the
Orlando World Center Marriott Resort and Convention Center in Orlando,
Florida, a new venue for the Institute starting in 2007. A complete listing
of the proceedings will be published here and is also available on the
Institute's Web site at http://www.law.miami.edu/heckerling.
We also will be posting the full text of each of these Reports on the ABA
RPPT Section's Web site, as we have since the 2000 Institute. Those Reports
can be found at URL http://www.abanet.org/rppt/meetings_cle/heckerling. In
addition, each Report can also be accessed at any time from the ABA-PTL
Discussion List's Web-based Archive at URL
http://mail.abanet.org/archives/aba-ptl.html.
===========================================================
This Report covers the Third Fundamentals Session that was held on Thursday
afternoon and presented by Jerry McCoy and Ed Beckwith plus the Thursday
Special Session 3-C about Decanting Discretionary Trusts plus Changes in
Rules in Charitable Gifts of Intangible Personal Property from Steve
Leimberg's January 17th Charitable Planning Newsletter. We anticipate that
the next Report will cover more of the Thursday sessions and the Wednesday
ever popular Q&A session (it's coming - we just are not sure how
soon). For those of you in the nonprofit sector, one of our future reports
will cover the Friday morning session about Charitable Contribution
Strategies that was presented by Conrad Teitell.
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Fundamentals Program #3 - Charitable Remainder Trusts Revisited
Thursday, January 17, 2008
Presenters: Jerry McCoy and Edward Beckwith
Reporter: Kimon Karas
The presenters started by stating this program was a fundamentals
program. The first item covered was a general overview. A charitable
remainder trust (CRT) combines both a private interest, the income stream
from the CRT and a public interest, the remainder that passes to charity.
Highlights of a CRT:
* Income stream to donor (other beneficiary);
* Payout to donor (beneficiary) is determined by donor;
* Trust may be an annuity trust, providing payment of a fixed amount
annually for the trust term or a unitrust, providing payments that vary
from year to year based on the value of the trust property;
* Charitable deduction allowable for the actuarial present value of the
remainder interest;
* The trust is exempt from federal taxes (provided it has no business
income or debt-financed income); and
* Trust document and trustee are required, and in certain cases a
trustee must be independent.
CRT is a trust where the donor transfers property to a trustee to be
held/managed for trust beneficiaries. IRC Section 664 and the regulations
set forth the requirements. CRT is referred to as a "split-interest trust"
since it combines charitable and noncharitable interests. IRS has ruled
that a CRT can only have one grantor; two are permitted if the grantors are
spouses.
There are two classes of beneficiaries, the current beneficiaries (may
include donor and donor's spouse as well as any others) and the remainder
beneficiary/beneficiaries, a charity or charities. A trust may provide
that rather than distributing the property to the charity/ that the trust
may continue for the benefit of the charitable remainder
beneficiary. Note, although the current beneficiary is oftentimes referred
to as an "income beneficiary" in order for the CRT to be qualified the
amounts the beneficiary/ies receive must be a unitrust or annuity amount
which amounts do not necessarily bear any direct relationship to the
trust's income.
The term of the trust may continue for the life of lives of the current
beneficiaries or for a term not to exceed 20 years. However, the actuarial
value of the remainder interest at the time of the trust's creation must be
at least 10% of the initial fair market value of the property transferred
to trust.
There are two types of qualified CRTs, a charitable remainder annuity trust
(CRAT) or a charitable remainder unitrust (CRUT). In both trusts the
amounts paid to the current beneficiaries is preset at the trust's
creation. In the unitrust the trust assets are determined each year and a
designated percentage of that value (no less than 5%) is distributable to
the beneficiary. In the annuity trust the amount distributable to the
current beneficiary is a fixed dollar amount determined at the trust's
creation and never changing.
There is also a hybrid CRT, the net income charitable remainder trust,
income only unitrust, where amount distributed to current beneficiary is
the trusts's earned net income if the trust does not realize enough current
income to make the required payout. Such a trust can include a make-up,
where future income can be used to make up past deficiencies,
NIMCRUT. There is also a Flip CRUT that commences as a net incme unitrust
that later "flips" to a standard unitrust paying a fixed percentage of the
trust's value, regardless of its income.
A CRT must be either a CRAT or CRUT, not both.
Generally trustee must make the annuity/unitrust payment within reasonable
period after close of taxable year for which payment is due.
A CRT will not be qualified if any trust provision restricts the trustee
from "investing its assets in a manner that could result in the annual
realization of a reasonable amount of income or gain from the
sale/disposition of its assets."
A CRT is generally exempt from all income taxes, including capital
gains. Be careful however if a CRT has UBTI the UBTI is taxed at
100%. Prior law if a CRT had UBTI it forfeited its tax exempt status.
The current beneficiaries are taxed on trust distributions under a
four-tier system: ordinary income, capital gain, other (tax-exempt income),
tax-free return of principal. Distributions are deemed to come first from
ordinary income, to the extent of the trust's ordinary income for the year
plus all undistributed income from prior years, the capital gains, current
and an undistributed, any remaining excess tax-exempt, and only after these
tiers are fully exhausted will distributions be return of principal.
Trust's taxable year must be calendar year.
Section 664(f) permits a CRT to contain a qualified
contingency. Ex. Income to wife for life, but if she remarries her
interest terminates and the remainder passes to charity.
A CRT must meet the definitions to qualify and equally as important be
administered and function exclusively as a CRT from its inception. A trust
is created at the earliest time that (i) no one is treated as the owner of
the trust under the grantor trust rule, and (ii) a trust will never be
deemed to be created before property is first transferred to it.
A CRT is treated as a private foundation for purposes of the self dealing
rules under Section 4941, prohibited transactions under Section 4945
(especially if the trust continues), also Sections 4944 and 4943.
To have a CRT there must be a trust document. IRS has published sample
instruments to be discussed later.
Best property to fund the CRT with is passive investments. Mortgaged
property among other issues can create UBTI as well as closely-held
business interests can create possible private foundation issues.
States' attorney generals have authority to assert supervision of such trusts.
CRUT
* Annual payment to the current beneficiary is fixed at a percentage of
the annual value of trust assets (not less that 5% nor greater than 50%).
* No invasion of principal other than to meet income payout
requirements, although additions may be made to principal in later years.
* Variable payment each year protects against inflation.
CRAT
* Annual payment to the current beneficiary is fixed at a sum or
percentage (not less that 5% nor greater than 50%) of the initial value of
the trust property.
* Inflation inures to benefit of remainder beneficiary.
* No subsequent contributions to the trust.
* Corpus cannot be invaded other than to meet payout requirements.
* 5% probability test. IRS imposed requirement of whether there is a
more than 5% probability that a noncharitable beneficiary will survive the
exhaustion of the trust corpus. This rule is not applicable to CRUTs.
Practical applications of CRTs. Common plan for clients who wish to
combine two often encountered objectives: a need for an income stream and a
charitable intent to transfer property to charity. Considerations include:
* Using CRT for stream of retirement income by selling a highly
appreciated large concentration of stock;
* Income stream for a dependent where client does not want dependent to
end up with asset;
* Use with a life insurance replacement trust. These must be
independent considerations. Oftentimes this is marketed as an insurance
sales device.
Planning Pointers.
* Carefully select investments. Trustee is subject to fiduciary
standards. Oftentimes advise is given to invest solely in tax exempt
bonds. Probably investing solely is one asset class is not prudent and
further under the tier system the likelihood exists that even with a
portfolio of high concentration in tax exempt bonds will not assure the
beneficiary of non-taxable income from the CRT.
* Section 2056(b)(8) and 2523(g) create a special estate tax and gift
tax marital deduction for the interest granted to a spouse in a
CRT. Caution cannot be any noncharitable beneficiary other than spouse.
* Charitable remainder in a QTIP trust. Since any beneficiary may be a
remainder beneficiary in a QTIP, a QTIP trust for the spouse (even with
principal invasion powers) with remainder to charity.
Drafting the CRT. The IRS has issued a series of revenue procedures that
provide sample trust documents. Each form is a free standing document.
CRUTS
* Rev Proc 2005-52, intervivos CRUT for one life;
* Rev Proc 2005-53, intervivos CRUT for term of years;
* Rev Proc 2005-54, intervivos CRUT for consecutive payouts for two lives;
* Rev Proc 2005-55, intervivos CRUT for concurrent and consecutive
payouts for two lives;
* Rev Proc 2005-56, testamentary CRUT for one life;
* Rev Proc 2005-57, testamentary CRUT for term of years;
* Rev Proc 2005-58, testamentary CRUT for consecutive payouts for two
lives;and
* Rev Proc 2005-59, testamentary CRUT for concurrent and consecutive
payouts for two lives.
For CRATS for same annuity payments refer to Rev Procs 2003-53-60.
Reliance on the forms the IRS will recognize the trust as qualified under
Section 664 and the Regulations if three tests are met:
* Trust "operates in a manner consistent with the terms of the
instrument creating the trust."
* Trust is valid under applicable local law.
* Trust is "substantially similar" to the sample forms (or properly
integrates one of more of the alternative provisions provided into a
document "substantially similar to the sample").
A trust that is not substantially similar merely loses automatic
qualification under the rev procs; it does not necessarily lose
qualification under the Code or Regulations.
The presenters then concluded the program by reviewing the full text of
Rev. Proc. 2005-59, the sample testamentary CRUT providing for unitrust
payments payable concurrently and consecutively for two measuring lives.
Rev. Proc. 2005-59.
Section 1 identifies purpose.
Section 2 gives background information including references to the other
published procedures.
Section 3 identifies the scope and objective.
Section 4 contains the actual trust document. Section 4 should be read in
conjunction with Section 5 that provides the annotations/legal authorities
for each of the applicable trust provisions and Section 6 that provides
alternative trust provisions. For example, Section 1 of the trust refers
to the payment of the unitrust amount. Section 5.02 includes 9 specific
annotations regarding Section 1 to the trust. Section 1 of the trust
provides the unitrust amount is to be paid to the noncharitable
beneficiaries ; whereas Section 6 of the Rev. Proc.illustrates language
where part of the unitrust payment is made to a charity.
The program concluded with a Q & A session.
====================================================
Special Session 3-C - Decanting Discretionary Trusts: State Law and Tax
Considerations
Thursday, January 17, 2008
Presenter: Alan Halperin
Reporter: Gene Zuspann
In the breakout session, Alan first addressed a question that had been
asked at the end of the regular session.
The question was "How do you decant?"
First, a two page document is created setting out the statutory
requirements, the details of the qualification to decant, and reason for
decanting. Second, a new trust is created by either the grantor or the
trustee. This new trust contains the provisions that are being changed.
Because only six states have decanting statutes, consideration should be
given to including decanting terms in the trust document. However, the
attorney must discuss this with the client. There will be times that the
provisions may not be desired by the client.
Alan H then started the discussion problems from his materials. The
discussions focused on those states that have decanting statutes. The
trustee and grantor must always consider the possible tax consequences of
decanting. A change in the trust has the potential of creating GST,
estate, gift and/or income taxes.
The first problem involved the desire to extend the termination date of a
trust. The existing trust was to terminate at the time that David turns
50, and the issue is whether the property could be retained in trust until
his death, then be distributed to his children. He said that this would
not qualify under the safe harbor rule in the statute because this changes
vested rights. If it is done, the new trust would have to give David a
general power of attorney to avoid a gift.
Problem two involves a trust that has two beneficiaries during the
grantor's life (child and grandchild). The remainder is payable to the
grantor's nephew. The trustee has full discretionary powers to distribute
among the two beneficiaries, but wants to decant to be able to include the
nephew as a permissible beneficiary during the grantor's life.
Alan concluded that you could accelerate the remainder interest in South
Dakota, but this is not permissible in the other states with decanting
statutes. However, the trustee may be able to decant to a new trust with a
limited power of attorney allowing an appointment to the nephew. He does
not believe that this change would constitute a gift by the existing
beneficiaries as long as no beneficiary who is a current permissible
beneficiary is not also a beneficiary under the new trust. If a
beneficiary of the existing trust is no longer a beneficiary of the new
trust, then there is probably a gift.
Problem three. An illiquid life insurance trust needs $400,000 to pay the
premium. The grantor had also created a GRAT that has since expired with
significant assets. Her husband and children are the beneficiaries of each
trust. Can the trusts be combined?
The conclusion is that you must look at the statutes of the applicable
state to determine whether the trustee could decant to a new trust. If
not, he said to consider a purchase of the policy by the trust with assets,
which may be a transfer for value. Also a loan by the trust with assets
could be made to the ILIT, but the interest paid by the ILIT would be
non-deductible.
Problem four contains two reciprocal trusts between a married
couple. There are two questions: "Is there an estate tax problem?" and
the answer is probably yes.
Can a new trust be created that is not reciprocal? The question is whether
state law allows decanting to create a new trust that is not
reciprocal? There is also a problem of inclusion under 2036, 2038 and 2042
which would trigger a three year waiting period under 2035.
Problem five contains a foreign trust with US source income. The desire is
to domesticate the trust. The main problem is whether the decanting
carries out DNI. If so, because it is currently a foreign trust, it will
also carry out UNI and the throwback rules will apply. One consideration
is whether the instrument allows an amendment. If so, it may be possible
to simply change the jurisdiction to the US. The argument is that this is
simply a continuation of an existing trust. However, if the changes are
substantial, the IRS may asset that the domestic trust is a new trust.
Problem Six: Can you decant to a new trustee in a different state to avoid
or limit state income tax?
In the facts of the problem, all contacts are with State X. The grantor,
the trustee and real estate all are located in State X. There are also
securities. Alan indicated that a problem is that a trust can't decant in
most states. This may make it difficult or impossible to decant and avoid
the state income taxes. In the facts, under the law of State X, an
irrevocable trust may not be taxed if no trustee, no real or tangible
property and no income is located or sourced in State X. However, if all
of these tests can be met, it may be possible to decant to a new trust in a
state with no state income tax and avoid the state income tax on the
capital gains and accumulated income.
When a decanting is done, the grantor of the original trust becomes the
grantor of the new trust for income tax purposes only. It may be possible
to decant only part of the trust not involving State X source income. To
avoid carrying out DNI, decant on January 1 and divide the trust.
Problem Seven: Can you decant to add a beneficiary? Alan does not know.
Problem Eight: A grantor creates a GST exempt trust with provisions "that
make it impossible to convert the trust to a grantor trust" for income tax
purposes. The grantor would now like to pay the income taxes on the trust
income. The first issue is qualifying under state law. If decanting is
possible, care must be taken not to change the beneficial interests. See
200743028. An unanswered question is whether converting a GST exempt trust
to a grantor trust is a shift of a beneficial interest. There are no regs
specifically on point.
If retaining the GST status of the trust is important, then Alan said that
he probably would not decant. Part of the decanting and the effect depends
on whether the decanting statute predates the trust.
Problem Nine: Wife created an ILIT with H and the children of the marriage
as the beneficiaries. H is also the trustee. The parties have divorced
and H wishes to continue paying the premiums on the policy. Alan suggested
that a new trust could be created. H needs to resign as trustee and as a
beneficiary.
Problem Ten: The grantor of a trust wants to modify the trust to change
administrative provisions, trustee succession provisions and investment
powers. The trust holds interests in an LP with a negative capital account.
The problem involves sections 643, 1001 and 752. The general rule under
643 is that a distribution to a new trust does not cause recapture of the
negative capital account. 643(e) does not apply to grantor trusts under
671 - 678. The issue is which rules trump - the rule that there is no
recapture or that the income is recaptured. If the trust is decanted, the
attorney must make sure that the client knows that the transaction may
cause a recapture of the negative capital account.
====================================================
Steve Leimberg's Charitable Planning Email Newsletter - Archive Message #132
Reprinted With Permission
Date: 17-Jan-08
From: Steve Leimberg's Charitable Planning Newsletter
Subject: Changes in Rules in Charitable Gifts of Intangible Personal Property
Richard L. Fox , a partner at Dilworth Paxson LLP in Philadelphia, PA, and
the Sallie B. and William B. Wallace Chair of Philanthropy and a Visiting
Associate Professor at the American College in Bryn Mawr, Pennsylvania,
where he heads the Chartered Advisor in Philanthropy® Program, is the
author of the treatise
<http://ria.thomson.com/estore/detail.aspx?ID=CGS&SITE=/taxresearch/federal>Charitable
Giving and Solicitation, a Warren, Gorham & Lamont/RIA publication, and is
a member of the editorial board of Estate Planning. He also writes a
national monthly bulletin on charitable giving and nonprofit topics, and
writes and speaks frequently on issues pertaining to philanthropy and
charitable giving.
Richard takes LISI members though a recent correction provision and
provides us with an excellent review of the state of charitable law with
respect to fractional contributions of tangible personal property.
EXECUTIVE SUMMARY:
In a welcome development, this technical correction avoids the potentially
catastrophic estate and gift tax impact that could have applied prior to
its issuance even though the "10-year rule" and the valuation limitation
for income tax purposes continue to apply to create a disincentive to
making fractional gifts of tangible personal property.
FACTS:
Background: Pension Protection Act of 2006 Created Substantial Disincentive
to Make Charitable Contributions of Fractional Interests in Tangible
Personal Property
In one of its most publicized and criticized provisions, the Pension
Protection Act of 2006 ("Act") made dramatic changes to the tax rules
applicable to contributions of fractional interests in tangible personal
property, including artwork, until that point, an increasingly popular
means of giving to museums. These changes created a substantial
disincentive for donors to continue to contribute such interests,
particularly in the context of the charitable gift and estate tax law.
Although a charitable contribution of less than an entire interest in
property is generally not deductible for income, gift or estate tax
purposes under the "partial interest rule," an exception is provided for a
contribution of a partial interest in property that represents a fraction
of the donor's entire interest in the contributed property. Thus, a donor
may transfer, for example, a 50% interest in artwork to a museum, thereby
giving the museum the right to posses the artwork 50% of the days of each,
and obtain an immediate tax deduction equal to 50% of the value of the
artwork.
Prior to the Act, there was no requirement that the donor transfer the
remaining interest in the artwork during his lifetime or, for that matter,
even at death.
As a practical matter, however, contributing an undivided interest in
artwork to a charity is generally limited to situations where the donor
ultimately intends to contribute the remaining interest to the same
charity. And, most museums won't accept a fractional gift of art unless
the donor agrees to give the remaining interest at some later date,
including upon death.
The technique of gifting fractional interests in artwork is ideal for an
owner of artwork who resides at the specific location where the works are
maintained only for a limited number of months during the year (who,
presumably, resides in better climates for the other months) and who
ultimately intends to make a testamentary disposition of the artwork to a
museum.
Changes to Contributions of Fractional Interests under Made Under the Act
The 2006 Act made significant changes to the existing income tax regime
governing contributions of fractional interests in tangible personal
property, with such changes also having application in the estate and gift
tax context. These are discussed below.
Recapture of Tax Benefits Under 10-Year Rule. There is now a recapture of
the income tax and gift tax charitable deductions (and, therefore, the
related tax benefits) if, within 10 years of the date of the initial
fractional interest or, if earlier, the donor's death, the donor fails to
contribute all of the remaining interest in the property to the same donee
organization.
There is also recapture of such deductions if, for the same period, the
donee fails to take substantial physical possession of the property and use
the property for its charitable purpose.[i]
Under these new rules, therefore, if a donor contributes an initial
fractional interest in a painting to a museum and then fails to contribute
all of his remaining interest to the same museum before the earlier of ten
years from the initial fractional contribution or the donor's death, the
donor's income tax and gift tax benefit for all previous contributions of
interests in the painting is lost, plus a 10% penalty applies.
The recapture provision would also apply if, during this same period, the
museum fails to take "substantial physical possession" of the property or
fails to use the property for its charitable purpose.
Fair Market Value of Subsequent Contributions Based on Value of Initial
Contribution. For purposes of determining the fair market value of each
additional contribution of a fractional interest in property following the
initial contribution, the Act provided that the fair market value for
purposes of determining the income, gift and estate tax charitable
deduction is the lesser of:
1. the value used for purposes of determining the charitable deduction
for the initial fractional contribution; or
2. the fair market value of the property at the time of the subsequent
contribution.[ii]
Thus, any appreciation in the property following the initial fractional
contribution would be ignored for purposes of determining the charitable
income tax deduction available for subsequent contributions, thereby
potentially severely limiting the value of any future income tax deduction.
Moreover, because this valuation rule applied to the gift and estate tax
charitable deduction, but not to the amount included in the gross estate or
the taxable gifts, the subsequent appreciation of the property will result
in negative estate and gift tax consequences.
For example, if a donor contributes a 25% interest in a painting worth
$10,000,000 to a museum in 2007 (taking a $2,500,000 charitable income and
gift tax deduction) and dies in the year 2014 when the painting is worth
$20,000,000, the estate tax charitable deduction for the contribution of
the remaining 75% fractional interest to the museum would be capped at
$7,500,000 (equal to 75% multiplied by $10,000,000), notwithstanding that
the $15,000,000 value of the donor's 75% interest in the painting is
included in the donor's gross estate. Thus, even though the museum
received a 100% interest in the painting during the requisite 10-year
period, the donor's estate is subject to estate tax in this situation on an
additional $7,500,000 in value, a terrible result.
Impact of Rules Under the Act
The appeal of making contributions of fractional interests of tangible
personal property, such as artwork, has always been that a donor can
continue to enjoy the property for a predetermined period of time each year
during his or her lifetime and that the income tax deductions for
subsequent contributions of fractional interests would be more valuable if
the property appreciates in value.
These benefits were removed as a result of the enactment of the Act.
Any donors otherwise willing to contribute the remaining interests in
fractional interests within 10 years of the initial contribution and
willing to forgo the possibility of a greater income tax deduction still
faced a major deterrent against contributing fractional interests because
of the potential negative estate and gift tax implications, should the
property substantially appreciate following the initial contribution of a
fractional interest. These potential negative consequences were generally
considered so significant that donors would generally be unwilling to
contribution fractional interests in tangible personal property.
Technical Corrections Act of 2007 Strikes Special Valuation Rule for Estate
and Gift Tax
Section 3(d) of the Technical Corrections Act of 2007 amends the provisions
of the Internal Revenue Code enacted under the Act that limited the amount
of the charitable gift and estate tax deduction for an additional
contribution of a fractional interest in property to the lesser of: (1) the
value used for purposes of determining the charitable deduction for the
initial fractional contribution or (2) the fair market value of the
property at the time of the subsequent contribution.
The result is this: Any appreciation in the property following the initial
fractional contribution will not be ignored for purposes of determining the
charitable gift or estate tax deduction available for subsequent
contributions, thereby removing the negative gift and estate tax
consequences contained in the Act.
However, the limitation of the value of the subsequent deduction for
charitable income tax purposes remains, as does the requirements the
remaining fractional interest be contributed within 10 years of the initial
contribution of a fractional interest. Such appreciation is still ignored
for purposes of any future income tax deduction and the additional
contribution deduction for income tax purposes is still limited to the
lesser of: (1) the value used for purposes of determining the charitable
deduction for the initial fractional contribution or (2) the fair market
value of the property at the time of the subsequent contribution.[iii]
THE BOTTOM LINE:
The gift and estate tax valuation limitation of the Pension Protection Act
of 2006 basically put a stop to most gifts of fractional interests of
artwork. Although this technical correction means that any subsequent gift
and estate tax charitable deduction is based on the value of the fractional
interest at the time of the subsequent gift and there is no longer a
"look-back" to the value of the interest as of the initial gift, the
overall limitations under the Pension Protection Act on gifts of fractional
interest of artwork still create a major disincentive to make such gifts.
CITE AS:
LISI Charitable Planning Newsletter # 132 (January 16, 2008) at
http://www.leimbergservices.com
Copyright 2008 Leimberg Information Services, Inc. (LISI). Reproduction in
ANY Form or Forwarding to ANY Person Prohibited - Without Express Permission.
CITES:
[i] IRC §§ 170(o)(3) (income tax); 2522(3)(3) (gift tax).
[ii] IRC §§ 170(o)(2) (income tax); 2522(e)(2) (gift tax); 2055(g)(1)
(estate tax).
[iii] IRC Sec. 170(o)(2).
====================================================
THE REPORTERS
Our on-site local reporters who are present in Orlando this year are Gene
Zuspann Esq. of Zuspann & Zuspann in Denver, Colorado; Joanne Hindel Esq.
of Fifth Third Bank in Cleveland, Ohio; Jason Havens Esq. of Howard, Mobley
& Havens PLLC in Florida and Tennessee; Kimon Karas Esq. of McCarthy,
Lebit, Crystal and Liffman Co., LPA in Cleveland, Ohio; Bruce Stone Esq. of
Goldman, Felcoski & Stone, PA in Coral Gables, Florida; Craig Dreyer Esq.
of McDonald Hopkins LLC in Cleveland, Ohio; Carol Sobczak Esq. of The Law
Offices of Carol A. Sobczak in St. Helena, California; Ronda Martinez Esq.
of Fifth Third Bank in Southfield, Michigan; and Mike Stiff Esq. of
Hutchins & Stiff LLC in Denver, Colorado. The editor again this year will
be Joseph G. Hodges Jr. Esq, a solo practitioner in Denver, Colorado, who
also is the Chief Moderator of the ABA-PTL List.
_________________________________________
GENERAL INFORMATION ABOUT INSTITUTE:
Inquiries/Registration:
Philip E. Heckerling Institute on Estate Planning
University of Miami School of Law
Center for Continuing Legal Education
P.O. Box 248087
Coral Gables, FL 33124-8087
Telephone: 305-284-4762 / FAX: 305-284-6752
Web site: www.law.miami.edu/heckerling
E-mail: heckerling@law.miami.edu
===========================================
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Telephone (407) 239-4200, FAX (407) 238-8777
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NOTICE: Although audio tapes of all of the substantive session at the Miami
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