SOUTHERN NEVADA ESTATE PLANNING COUNCIL

Lunch will begin at 12:00 p.m., then we will welcome our featured speaker, Christopher P. Siegle., at 12:30 p.m.

Reminder that any guest registrants must be sponsored by a returning member of SNEPC! Please contact admin@southernnevadaepc.org with any questions.

Selling Assets to a Non-Grantor Trust

A nuts-and-bolts session for planners who want to move beyond the standard grantor-trust sale and understand when a GST-exempt non-grantor trust can deliver meaningful transfer-tax and income-tax leverage. The presentation treats the non-grantor trust as an opportunity, especially in a world where most affluent clients are not transfer-tax payers but still face real income-tax friction and real planning constraints. 

Expect crisp guidance on execution and on what can go wrong. This presentation walks through installment-method eligibility (and ineligible property), the related-party timing rule that can trigger accelerated gain if the trust disposes of assets too soon, and the deficiency-interest regime that can change deal sizing and pacing.  It also tackles the promissory-note “endgame,” including why note disposition can accelerate gain and why the merger doctrine can create ugly income-tax consequences if the note ever returns to the issuing trust. 

Christopher P. Siegle is the Senior Wealth Advisor and a Managing Director at J.P. Morgan Private Bank in Phoenix. Before joining J.P. Morgan in 2010, Chris was a partner at a regional law firm in Phoenix, where he practiced for over 13 years in trust and estate, tax, and business planning. He is a Fellow of the American College of Trust and Estate Counsel (ACTEC), a Life Fellow of the American Bar Foundation (ABF) and holds the Accredited Estate Planner (AEP®) designation. He is a national speaker on tax and estate planning and has authored articles and book chapters on these topics. In academia, Chris is an Adjunct Professor of Law in both the Graduate Tax Program at Villanova University School of Law, and Loyola Law School. He holds an LL.M. in taxation from Villanova University, an M.S.S. from the United States Army War College, a J.D. with Honors from the University of Tulsa College of Law, and an A.B. from the University of Illinois at Urbana-Champaign. Chris is a retired Captain in the United States Navy, having served from 1990 to 2020.