Seth Kelly

Saving business owners & professionals MILLIONS in income & estate taxes while also growing assets. I do all the work needed for the plan, so you don't have to!

[Seth Kelly @Seth_Convergent]

Here is how a special type of charitable trust and a LLC can be a powerful estate planning strategy while also providing charitable benefits!

First let's discuss the Charitable Remainder Unitrust or CRUT. The trust we will be talking about later will be a type of CRUT.

[SuperTalk Mississippi @supertalk]

THE DECISION: Ole Miss Athletic Director @KeithCarterOM talks about when @Lane_Kiffin was informed that he would not be coaching the Rebels in the College Football Playoffs...

[Ole Miss Football @OleMissFB]

Ain’t playing scared.
Ain’t coaching scared.
Ain’t going anywhere.

Welcome to the Golding Era 🦈

@CoachGolding | #HottyToddy

[Ole Miss Football @OleMissFB]

Locked in for the @CFBPlayoff 🔒

[Ole Miss Football @OleMissFB]

Leader of Men.

#GOLDingEra 🦈

[Seth Kelly @Seth_Convergent]

@83lease @rledbetterCPA Typically assign a small % to spouse/trust for spouse

[Seth Kelly @Seth_Convergent]

@MONEYnMEATBALLS @baldridgecpa For QSBS eligible corporations, your LLC basis is 10x’ed upon conversion to C-Corp or the greater of the $15mm exemption.

[Seth Kelly @Seth_Convergent]

@DallasAptGP Thank you for this breakdown! I’m assuming in your example that all (or most) of the multiple projects will also have to be QOZ property so to abide by the 90% asset test?

[Seth Kelly @Seth_Convergent]

What state does he reside in and has there been any IOI/LOIs discussed yet? He could possibly look into doing some marital gifting and completed gifts into non grantor trusts in a favorable state jurisdiction. If the sell qualifies for QSBS, then this could make it completely tax free with QSBS stacking.

Other low hanging fruit items are QOZ and DAF.

[Seth Kelly @Seth_Convergent]

@natesosa_CPA Awesome thread! Was he not able to do a grouping election for the properties?

[Seth Kelly @Seth_Convergent]

I would also suggest looking into some trust planning since the lifetime exemptions are still at $14mm/$28mm. Heirs lose the step up but avoid a potential fire sale of assets to pay estate taxes.

He could possibly utilize SLATs if married or IDGTs. Maybe also do a mixture of gift/sale of assets to trusts.

[Seth Kelly @Seth_Convergent]

@LorilynWilson I really wish he would read this IRS MEMO on this exact structure

https://t.co/Vc9818pcr5

[Ole Miss Football @OleMissFB]

Judges for the Grove Bowl Dunk Contest 🏀

#ComeToTheSip

[Brad Logan @BradLoganTOC]

Former Ole Miss WR AJ Brown (⁦@1kalwayopen_⁩) signing autographs here at the Grove Bowl Games.

#OleMiss | #GroveBowlGames

[Trey Wallace @TreyWallace]

They’re having a sorority tug-of-war during the Ole Miss ‘Grove Bowl’

We’ve reached new standards of spring football. This is some funny stuff

[Ole Miss Rebels On SI @OleMissOnSI]

Joey Chestnut is present for the "Grove Bowl Games" at #OleMiss on Saturday, but he is hoping for a return trip this fall for an actual game.

The champion eater is a legit college football fan. #HottyToddy

https://t.co/EFCQfWvgH1

[Trey Wallace @TreyWallace]

Ole Miss DB Brandon Turnage wins the dunk contest during Rebels ‘Grove Bowl’

[Seth Kelly @Seth_Convergent]

Thanks for posting this Christopher!

Do you know the income tax nature of the trust? For reference, if the grantor has REPS, would they benefit from the losses the Trust properties generates (bonus depreciation)?

Material participation can get tricky with trusts so wondering if you have any insight on this!

[Seth Kelly @Seth_Convergent]

@ForemanTaxLaw Mitt Romney, is that you?

[Seth Kelly @Seth_Convergent]

@InformedByIan @MatthewWidmyer @TKopelman Trusts can have holdco entities in which the manager of the entity is the grantor of the trust. Investment decisions of this holdco can be made at the entity level. So the manager may be able to purchase a professional team while being indirectly owned under a trust structure.

[Seth Kelly @Seth_Convergent]

@MatthewWidmyer @InformedByIan @TKopelman Spousal Lifetime Access Trusts (SLATs) are definitely an option that removes assets out of one’s estate.

Trusts nowadays are a lot more flexible than they were decades ago.