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​Multilevel, Sophisticated Estate Planning for a Wealthy Client and His Family

An elderly client needed assistance developing a strategy for a family limited partnership funded with marketable securities. The client implemented a gifting program, giving partnership units to his children and valuing these gifts at a discount as non-marketable minority interests.The Quarles & Brady team assisted the client in the proper management of the partnership during his lifetime—so well that the client's estate tax return was accepted without audit—and upon his death, his son (also a client) used the partnership units to fund a Grantor Retained Annuity Trust (GRAT). At the conclusion of the GRAT, the partnership units will be distributed to the son's children at a substantial discount and without additional transfer tax.