William S. Friedman

Assisting clients in the preparation of their wills, trusts, powers of attorneys and healthcare documents with an eye to internal family dynamics and the family members' abilities to handle fiduciary and business decisions. This process often includes consideration as to whether non-family executors and trustees may benefit the estate or trust administration. Drafting a range of documents, including revocable living trusts for lifetime management of assets or out-of-state real property to avoid probate, as well as durable powers of attorney for financial and healthcare decisions, Durable Powers of Attorney (DPA), healthcare directives and living wills, Health Insurance Portability and Accountability Act (HIPAA) authorizations for release of protected healthcare information and premarital and postnuptial property status agreements that clarify status of community and separate property.

Advising non-U.S. clients on the creation, funding and administration of foreign revocable and irrevocable trusts, including gift and insurance trusts, pre-immigration planning, ownership of U.S. and non-U.S. assets and compliance with U.S. reporting requirements. Advising U.S. clients on the ownership of foreign assets and compliance with reporting requirements, including the Offshore Voluntary Disclosure Program.

Advising clients on multi-generational estate and asset planning for families owning large operating businesses.

Providing ongoing consultation with active multi-functional family offices on a wide range of tax, investment management, estate planning and governance matters.

Providing advice on tax-efficient gifting to children and grandchildren, including drafting and implementing "Crummey" Trusts, Generation-Skipping Trusts, Residence Trusts (QPRT), Grantor Retained Annuity Trusts (GRAT) and Irrevocable Life Insurance Trusts (ILIT). Assisting clients with education savings planning, including tax effects of 529 Plans, and providing advice on tax efficient giving to charities, including Charitable Lead Trusts and Charitable Remainder Trusts (CLAT, CLUT, CRAT and CRUT). Preparing estate and gift tax forecasts and plans for payment of estate taxes for business succession.

Establishing limited liability companies (LLCs) and family limited partnerships (FLPs) for the management of family real estate and other assets among multiple generations of the same family.

Assisting clients in establishing private foundations or charitable trusts to hold family assets. Preparing gift agreements with various educational or charitable institutions. Preparing applications for tax-exempt status and representing client organizations before the Internal Revenue Service.

Advising clients on estate and trust administration, probate, estate and trust dispute resolution matters and the preparation of gift and estate tax returns, including:

• Representing executors or administrators (aka personal representatives) of estates and trustees of trusts in the fulfillment of fiduciary duties.
• Representing beneficiaries regarding their interests in estates and trusts.
• Advising and drafting nonjudicial binding agreements to modify will or trust terms.

Preparing gift tax returns to report taxable gifts and federal and Washington estate tax returns, as well as representing taxpayers on estate and gift tax audits.