Syracuse Law Review
Prior to Chapter 14, a commonly-recommended estate tax reduction strategy was what practitioners and others referred to as “corporate estate freezes.” This strategy was pertinent to families with substantial wealth that were involved in one or more closely held businesses. In the corporate context, it typically involved recapitalization of a family business to a multi-stock corporation, followed by the transfer (either by gift or purchase) of one class of stock, the perceived growth stock, to children and grandchildren.
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