We are looking for a tax attorney, CPA, or other financial advisor to provide us a comprehensive strategy for the following client / fact pattern.
CLIENT (US citizen and California resident over 65 years old)
Total asset value under $5M, including all of the following assets.
- Traditional IRA
The following assets are currently held in a revocable trust with Client as the sole trustee.
- Stock Portfolio producing capital gains
- Primary Residence with low basis (would like this to be sold to take advantage of the home sale exclusion)
- Rental Property1 with low basis (currently producing rental income and will likely not be sold)
- Rental Property2 with high basis (will be sold shortly)
WIFE (US citizen and California resident almost 65 years old)
No assets of her own.
STEPSON1 (son of Wife from previous marriage; US citizen and California resident around 35 years old)
Has the following assets.
- 35% stake in a California LLC (taxed as an S corporation) generating a little income.
- 100% stake in a sole proprietorship generating a little income.
- Will have a Startup Company, subject to the financial planning goals below. The Startup Company is expected to generate negative income for the first few years.
STEPSON2 (son of Wife from previous marriage; US citizen and California resident around 35 years old)
Has moderate income (less than $100,000 per year).
FINANCIAL PLANNING GOALS
- Decrease Client's income tax / AMT. Client is currently subject to the AMT.
- Transfer Client's assets as venture capital or venture debt to fund Stepson1's Startup Company.
- Transfer as much of Client's assets to both Stepson1 and Stepson2 within the next 5 to 10 years.
- Client shall retain some assets in a revocable trust for personal living expenses for Client and Wife.
- Transfer remaining assets (if any) to Wife upon death of Client.
FINANCIAL PLANNING VEHICLES
Client is willing to consider any of the following options, as well as any others proposed by the freelancer.
- Invest in Startup Company, with the Startup Company being a Hong Kong limited company, Taiwan limited company, California LLC taxed as an S corporation, California S corporation, or any other suitable arrangement.
- Sell any of the real properties to either Stepson1 or Stepson2 via a seller-financed mortgage / installment sale, with a loan forgiveness clause.
- Provide low interest loans to either Stepson1 or Stepson2, with a loan forgiveness clause.
- Pending sale of Primary Residence, live in either Rental Property1 or another home.
- Have a revocable trust for living expenses, and an irrevocable trust for any assets to be transferred to Stepson1 or Stepson2.
- Trusts can be in the form of any of the financial planning vehicles, including QTIP, QPRT, GRAT, etc.
To be considered for this project, please respond to the screening question below. Thank you.