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Let’s Make a Deal! Minimizing Tax Costs in Asset Sales as Part of the Sale of the Family Business  


Author:  Gerald R. Nowotny.


Source: Volume 37, Number 02, Winter 2020 , pp.21-32(12)




Journal of Taxation of Investments

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Abstract: 

The author explains how to combine the use of a charitable remainder unitrust (CRUT), with a C corporation as the settlor or grantor of the CRUT, and a Malta Pension Plan in order to eliminate taxation on the liquidation of the corporation. The strategy works to (1) minimize and defer corporate-level taxation and (2) eliminate taxation upon the liquidation of the corporation.

Keywords: Charitable Remainder Unitrust, Malta Pension Plan, Charitable Deduction, UBTI Concerns

Affiliations:  1: Office of Gerald R. Nowotny.

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