Taking Note of the Note in IDGT Sales

Date: Tuesday, March 26, 2024
Time: 5:30pm - 8:00pm
Location: Pacific Club, 4110 MacArthur Boulevard, Newport Beach 92660
Speaker: Jonathan C. Lurie, Willkie Farr & Gallagher, LLP


IDGT sales often result in a large note.  This note has significant estate planning ramifications and this is the subject of this lecture. One of the first questions is whether this  sale is in fact a sale and whether the debt is valid and effective consideration in the transaction. These sales are seldom arms-length and there are seldom independent lawyers on both sides of the transaction. It would be better if there were. There is nearly always an appraisal from an independent appraiser that establishes the value of the sale. This is very important. The IRS does not like transactions close to death and particularly where the one party is represented by someone acting on a  power of attorney. Join us to learn more about IDGT sales.

Jonathan Lurie is senior counsel in the Private Wealth Group, where he focuses on U.S. and international tax and estate planning and trust administration. Jonathan is a problem solver who uses his significant experience to develop personalized wealth management and preservation strategies to achieve the individual objectives and aspirations of the clients he serves.

Chambers High Net Worth 2023 ranks Jonathan as a top advisor for Private Wealth Law in California, where he is commended for being "an excellent attorney with extraordinary experience" and "extremely knowledgeable." Chambers also notes, “He's always helpful and a pleasure to work with."

A native South African, Jonathan has practiced law in South Africa and the United States. He attended university and law school in Johannesburg, South Africa, and is admitted to practice law in the Republic of South Africa and Kingdom of Lesotho, in addition to California.

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