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D. Randall Gibson

Work Highlights

Family Business Succession Planning and Estate Planning with Special Trusts

Represented husband and wife in planning for their business and estates by restructuring the company into voting and nonvoting shares, allowing them to transfer value while maintaining control, and preparing and implementing a stock restriction agreement, a multi-generation family protection trust, traditional A/B trust planning, essential planning, a qualified personal residence trust, a vacation home trust, and gifting trusts for each grandchild.

Family Estate Planning with Private Family Foundation and Charitable Lead Trust

Represented husband and wife in planning for their family and multi-million dollar estates by preparing and implementing multi-generational spousal limited access irrevocable trusts, traditional A/B trust planning, essential planning, a charitable lead annuity trust and a private family foundation.

Family Business Succession Planning- Sale to Grantor Trusts- Charitable Planning

Represented multi-generation family in planning for their family and estates after the sale of the family business, including preparing and/or implementing Delaware Trusts, a charitable lead annuity trust, limited liability companies, sale to dynasty trusts and valuation discounts as well as assisting in the administration of the estates of several family members after their unexpected deaths.

IRS Audit of Estate Tax Return- Family Limited Partnership-Graegin Loan

Represented a multi-million dollar estate in an Internal Revenue Service audit of the Federal estate tax return and a family limited partnership structure. Successfully defended the validity of the family limited partnership, obtained a significant valuation discount and successfully used a Graegin loan to finance the payment of the Federal estate tax.

Reorganization of Equine Business, Insurance Trust and Gift Planning

Represented a husband and wife in planning and implementing the reorganization of a multi-million dollar equine business; in the preparation of multi-generation irrevocable trusts for each of the children and the gifting of interests in the equine business on a discounted basis to the trusts; in planning and implementing a multi-million dollar life insurance trust; and in preparing and implementing a beneficiary defective irrevocable dynasty trust.

Trust Reformations- Delaware Directed Trusts

Represented a corporate trustee in amending multiple 1950s trusts to be directed trusts, transferring administration of the trusts to Delaware and obtaining a private letter ruling from the Internal Revenue Service to confirm the continuing applicability of the generation-skipping tax grandfathered exempt status of the trusts.