N. Todd Angkatavanich

Partner – US Regional Division Co-Leader, Private Client & Tax Group; Co-Leader, Family Enterprise Special Interest Group

  • Education: Fairleigh Dickinson University, magna cum laude, B.A. • Rutgers University School of Law, Tax Law Honors, Campbell Scholar, • Rutgers Graduate School of Management, M.B.A. • New York University School of Law, Taxation, LL.M.
  • Admitted: State of NJ, 1993 • State of NY, 1995 • State of CT, 2006 • Registered Foreign Lawyer in the UK, 2007
  • Year joined: 2005
  • Year became partner: 2007

Overview

Todd co-heads the firm's Private Client & Tax Group in the United States. His practice is focused on tax, trusts and estates, and business succession matters for affluent individuals and their families.  He regularly advises domestic and international families and family offices with respect to creating trust and related business structures to preserve, protect and grow family wealth for multiple generations in a tax efficient manner.  

Todd has significant experience working with clients to structure US and international wealth preservation vehicles such as Family Limited Partnerships, Grantor Retained Annuity Trusts, Sales to Intentionally "Defective" Grantor Trusts, Foreign Grantor Trusts, Qualified Personal Residence Trusts, Buy-Sell Agreements and Preferred Freeze Partnerships.  He also advises clients on business succession matters, with a particular emphasis on navigating the various tax pitfalls under Chapter 14 of the Code.  In addition, Todd's practice also involves the preparation of estate planning documents for clients including "tax-sensitive" Wills and Revocable Trusts, Generation-Skipping Dynasty Trusts and Irrevocable Life Insurance Trusts.  Todd also has experience in advising Hedge Fund and Private Equity Fund professionals with respect to transferring carried interests into multi-generational trusts for the benefit of younger family members in a tax-efficient manner.

Todd has been published in Trusts & Estates, Private Wealth, Estate Planning, ACTEC JournalBNA Tax Management, Probate & Property, Private Asset Management and other publications.  He is also the co-author of BNA/Tax Management Portfolio, No. 875, entitled "Wealth Planning With Hedge Fund and Private Equity Fund Interests and Related Section 2701 Issues."

Todd is a frequent speaker on estate planning topics such as Family Limited Partnerships, Business Succession Planning and related Chapter 14 issues.  He has given presentations, webinars and teleconferences for various organizations including the Heckerling Estate Planning Institute, the Federal Tax Institute of New England, the ABA Section of Real Property Trust & Estate Law (Spring Symposia, Fall Joint Meetings and Skills Training Programs), the Notre Dame Tax and Estate Planning Institute and the Seattle Estate Planning Seminar, as well as numerous estate planning councils, CPA societies and professional organizations.  He has been rated AV Preeminent® by Martindale-Hubbell® Peer Review Ratings™ and has been listed in Who's Who Legal: Private Client. Todd has been quoted in articles that have appeared in Barron's, Bloomberg Businessweek, The Boston Globe, The Philadelphia Inquirer, The Chicago Tribune, The Miami Herald, Forbes, MSN Money and other publications.

 Todd also serves as a member of the firm's Pro-Bono Committee and its Diversity Committee.

Highlights

  • Fellow, American College of Trust and Estate Counsel (ACTEC)
  • Faculty, 2012, 2015- 2018 Heckerling Estate Planning Institute
  • Editorial Board, Trusts & Estates magazine; Co-Chair, Estate Planning & Taxation Committee
  • Chair, Wealth Planning Advisory Board, BNA/Tax Management Estates, Gifts and Trusts
  • Planning Committee and Faculty, Federal Tax Institute of New England
  • Co-Chair, Business Planning Group - Business Investment Entities Committee of the American Bar Association, Real Property, Trust & Estate Law Section
  • 2017 Trusts & Estates Distinguished Authors Awards Winner in Philanthropy Planning
  • 2016 Martindale-Hubbell® AV Preeminent® Special Edition Judicial Award for Highest Possible Rating in Both Legal Ability & Ethical Standards
  • Ranked in Chambers HNW 2016
  • Faculty, 2015 Notre Dame Tax & Estate Planning Institute
  • 2012 "Private Client Lawyer of the Year" Award, FOR (Family Office Review) Awards, North America, Chicago
  • Faculty, 2013, 2014, 2015 and 2016 ABA/RPTE Skills Training Program (Advanced Topics)
  • Fellow, American Bar Foundation
  • Executive Committee, Connecticut Bar Association, Estates & Probate Section
  • Member, ABA/RPTE Diversity Committee
 

Publications and speaking engagements

Recent Speaking Engagements:

  • "Warming Up to Preferred Partnership Freezes,"51st Annual Heckerling Institute on Estate Planning, Orlando,FL, January 2017.
  • "Frozen Tasting Menu - A Comparison of GRATs, Sales to Grantor Trusts and Other Estate Freezes," 51st Annual Heckerling Institute on Estate Planning, Orlando, FL, January 2017.
  • "Hot Topics," American Law Institute, Estate Planning For the Family Business Owner 2016, Dallas, TX, November 2016.
  • "Wealth Transfer Planning with Carried Interest in Hedge Funds and Private Equity Funds," 38th Annual Duke University Estate Planning Conference, Durham, NC, October 2016.
  • "Chapter 14: 'Soup to Nuts' -- A Practitioner's Guide Through the Minefield," "Avoiding the Mismatch: Pitfalls and Various Estate Planning Structures," and "Best Practices for Estate Planning Attorneys (Panel Discussion)," Ohio State Bar Association's 27th Annual Conference on Wealth Transfer, Columbus, OH, June 24, 2016.
  • "The Global Family: Capital Flows and Wealth Preservation," Armonk, NY, June 2016.
  • "Avoiding International Entanglements for the Domestic Estate Planning Attorney," ABA RPTE Spring Symposia, Boston, MA, May 2016.
  • "Chapter 14 Soup to Nuts: A Practitioner's Guide Through the Minefield," 50th Annual Heckerling Institute on Estate Planning, Orlando, FL, January 11-15, 2016. 

  • "Wealth Transfer Planning with Interests in Private Investment Funds and Other Closely-Held Entities," 50th Annual Heckerling Institute on Estate Planning, Orlando, FL, January 11-15, 2016.

  • Interviewed, "Financial Gravity: How to Talk to Your Kids About Money," Forbes, November 23, 2015. Click here to listen.

  • "The A-Z of Insurance Dedicated Funds & the Benefits of Tax Deferred Growth," 2nd Annual Hedge Fund IDF Symposium, Fort Lauderdale, FL, November 5, 2015.

  • "Mismatch Rematch: Re-Aligning the Estate Plan to Avoid Unexpected Pitfalls," Annual Federal Tax Institute of New England, Portland, CT, October 30, 2015.

  • "What Every Domestic Estate Planning Attorney Should Know About International Estate Planning," American Bar Association Business Planning Group, October 2015.

  • Podcast on "Section 2701 Essentials," Leimberg Information Services, October 2015. Click here to listen.

  • "The Preferred Partnership Freeze and the Reverse Freeze" and "Planning Applications for Carried Interests, Private Equity Partners and Hedge Fund Partners," 41st Annual Notre Dame Tax & Estate Planning Institute Conference, South Bend, IN, September 2015.

  • Interviewed, "Business Transition Planning: How to Leave Your Company to Your Children," Forbes, August 11, 2015.

  • "Attributes of a Family Enterprise: Utilizing the Asset Holdings Structure to Facilitate Business and Operational Success," Opal Financial Group's 2015 Family Office & Private Wealth Management Forum, Newport, RI, July 2015.

  • “Planning with SCINs and Private Annuities – Seizing Opportunities While Navigating Complications,” 49th Annual Heckerling Institute on Estate Planning, Orlando, FL, January 2015.

  • “Avoiding the Adverse Effects of Chapter 14 For Closely Held Business Interests, Including Planning Applications and Considerations,” Federal Tax Institute of New England, Hartford CT, October 2014.
  • “Closely Held Business Planning with Chapter 14 Implications,” ABA RPTE Skills Training Program (Advanced Topics), New York, NY, July 2014,  2015 and 2016.
  • “Planning with Estate Freezes, GRATs and Sales to Defective Grantor Trusts” ABA RPTE Skills Training Program (Advanced Topics), New York, NY, July 2014.
  • “Family Limited Partnerships With Section 2036 Implications,” ABA RPTE Skills Training Program (Advanced Topics), New York, NY, July 2014, 2015 and 2016.
  • “Achieving ‘Business Certainty’ with Buy-Sell Agreements,” NYSCPA Society Annual Estate Planners Day, New York, NY, May 2014.
  • “Tarnish-Proof Your Plan: Avoiding the Whipsaw of Valuation Mis-matches in Entity Planning,” ABA/RPTE 2014 Spring Symposia, Chicago, IL, May 2014.
  • “How to Make the Grade and Grade a Valuation Report,” ABA/RPTE 2014 Spring Symposia, Chicago, IL, May 2014.
  • “Set It – But Don’t Forget It! Avoiding the Devil in the Details in Administration of Estate Planning Vehicles” CBA Estates & Probate Section, New Haven, CT, April 2014.
  • “IRS Continues Attack of Estate Planning Practices under Chapter 14 Valuation Rules,” ABA Business Planning Group, March 2014.
  • Bloomberg BNA webinar on “Best Tips to Structure & Administer a Family Limited Partnership,” February 2014.
  • “The Preferred Partnership GRAT,” InterActive Legal Booth Lecture Series, Orlando, FL, January 2014.
  • “Wealth Planning with Hedge Fund and Private Equity Fund Interests,” “Breakfast with Bloomberg BNA Authors,” Orlando, FL, January 2014.
  • Video lecture on “The Preferred Partnership GRAT” for Trusts & Estates magazine, January 2014.   Please click here to view this lecture on wealthmanagement.com. 
  • "Essentials of Chapter 14: A Practitioner's Guide Through the Minefield," 58th Annual Seattle Estate Planning Seminar, Seattle WA, October 2013.
  • "Transfer Tax Planning with Carried Interests in Hedge and Private Equity Funds," ABA Section of Taxation and Section of Real Property, Trust and Estate Law, Trust and Estate Division, 2013 Joint Fall CLE Meeting, San Francisco CA, September 2013.
  • "A Ten Point Diagnostic Test of Your Family Limited Partnership," 46th Annual Heckerling Estate Planning Institute, Orlando, FL, January 2012. Watch Todd discuss this presentation on Trusts & Estates' Industry Insights Live from Heckerling. 

 

Recent Publications:

  • Co-Author, "Foreign Affairs : A Primer on International Tax and Estate Planning (Part 1)," BNA/Tax Management Estates, Gifts and Trusts, July 2017.
  • Co-Author, "When Art Pops in Value..." STEP Journal, March 2017.
  • Quoted, "Charity May Be Answer to Looming Deferred Compensation Deadline," Tax Notes, January 10, 2017.
  • Quoted, "One-Year Countdown on Offshore Funds Begins" Accounting Today, January 3, 2017.
  • Co-Author, "Mark-to-Market Freezes – Freeze Planning in an Estate Tax-Free Environment," LISI Estate Planning Newsletter #2480, November 2016.
  • Co-Author, "Comments on Proposed Treasury Regulations Concerning the Valuation of Interests in Corporations and Partnerships for Estate, Gift, and Generation-Skipping Transfer (GST) Tax Purposes," American Bar Association Section of Real Property, Trust & Estate Law, November 2016.
  • Co-Author, "The Rising Tide Carry CLAT," Trust and Estates, October 2016.
  • Quoted, "Keeping it in the Family," Private Asset Management, October 2016.
  • Quoted, "IRS Proposal Forces Families in Gifting Frenzy," Private Asset Management, August 2016.
  • Co-Author, " No Strings Attached," STEP Journal, Volume 24/Issue 7.
  • "Carried Interest Wealth Planning for the Global Fund Manager: An Introduction to Carry Planning and Implications in the International Context,Bloomberg BNA Tax Management Estates, Gifts and Trust Journal, August 2016.
  • "Tax Court Decision Clarifies Treatment of Intergenerational Split-Dollar Life Insurance Arrangement," Withers Bergman Tax Alerts, May 2016.
  • "CLAT Planning to Mitigate Income Tax on Bringing Deferred Compensation Onshore in 2017,"Withers Bergman LLP, April, 2016.
  • "Todd Angkatavanich & James I. Dougherty on the Davidson $320 Million Settlement:  Finding Opportunity in Light of the Taxpayer Victory in the Davidson $320 Million Settlement While Being Mindful of the Uncertainty from CCA 201330033," Leimberg Information Services, Inc. Estate Planning Newsletter #2322, July 14, 2015.
  • "To Boldly Go Where No Man (or Woman) Has Gone Before: Some Random Thoughts on Estate Planning Past, Present and (More Important) Future," Trusts & Estates magazine, September 2014.
  • "IRS Attacks Common Estate Planning Technique in Estate of Woelbing," Connecticut Bar Association, Estates & Probate Newsletter, June 2014.
  • "Trusts Can Materially Participate in Trade or Business: Taxpayer Victory in Frank Aragona Trust v. Commissioner, " wealthmanagement.com, April 2014.
  • "Gift Planning With Formula Clauses: From Procter’s Progeny to Wandry World (Part 2)," Probate & Property magazine, Mar/Apr 2014.
  • "Gift Planning With Formula Clauses: From Procter’s Progeny to Wandry World (Part 1)," Probate & Property magazine, Jan/Feb 2014.
  • "Implementing Early Inheritances: The why and how of giving sooner while living longer," Trusts & Estates magazine, December 2013.
  • Quoted, "Same-Sex Marriage Tax Tips," Chicago Tribune, September 1, 2013.
  • "Structure and Integration: The Architecture of Succession," FFI Practitioner, August 2013.
  • "On the Horizon: Estate Planning Developments," Tax Stringer, June 2013.
  • "Practical Gift Funding Issues When Planning with Hard-to-Value Assets," Connecticut Bar Association, Estates & Probate Newsletter, May 2013.
  • "Coming Ashore - Planning for Year 2017 Offshore Deferred Compensation Arrangements: Using CLATs, PPLI and Preferred Partnerships and Consideration of the Charitable Partial Interest Rules," ACTEC Law Journal, Spring/Fall 2013.
  • Quoted, "Coming Changes in Estate Gift Taxes Stir 'Frenzy'," Bloomberg Businessweek, October 2012.
  • Featured in "Stress-Test, Family Business Style," Fairfield County Business Journal, May 2012.
  • "Planning for Certainty in Business Direction and Succession," FFI Practitioner, May 2012.
  • "Preferred Partnership Freezes," Trusts & Estates magazine, May 2011.
  • "Non-Vertical Carried Interest Transfer Planning-An Alternative to the Vertical Slice," Private Asset Management, March 2011.
  • "Going Non-Vertical with Fund Interests - Creative Carried Interest Transfer Planning When The "Vertical Slice" Won't "Cut It," Trusts & Estates magazine, November 2010. 
  • "Pre-Liquidity Planning - Do It Now," Trusts & Estates magazine, April 2010.
  • "The Preferred Partnership GRAT: A Way Around the ETIP Issue?," ACTEC Law Journal, Winter 2009.

Please click here to see a complete list of Todd's publications and speaking engagements

Memberships

  • American College of Trust and Estate Counsel (ACTEC)
  • American Bar Association
  • Connecticut Bar Association 
  • New Jersey Bar Association
  • New York State Bar Association
  • Society of Trust and Estate Practicioners (STEP)

On a personal note

Todd enjoys cooking, wine, writing and recording music, golf and boating.  In his spare time, Todd enjoys spending time with his wife, Lauretta, their two children and their two Labrador Retrievers.

  

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