The Future of Main Street Business Succession In 2001, veteran investment banker, Peter Christman, first identified the need for a holistic approach to preparing owners of midmarket businesses for sale and/or exit. He set about writing a book to address this. At the time, the first Baby Boomer was 56 years of age. Those Baby Boomers are now not so young. In this article, the author shares his impression of the challenges Main Street business owners and business succession advisors face developing a plan and executing the exit plan. A Brief History Depending on how you mark the start date,…
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Estate of Morrissette v. Commissioner, 146 T.C. No. 11 (April 13, 2016) The Tax Court’s ruling in Morrissette is very important to the estate planning community, in that, intergenerational split-dollar life insurance arrangements have become much more popular since the IRS released its final split-dollar regulations in 2003. Yet, widespread use of this technique has been suppressed by uncertainty with respect to the tax result. Further, the IRS has oftentimes taken the position (in audits) that a lump sum premium payment should be treated as a gift to the lower generation even if the economic benefit regime was used to…