DPCEPC: The One Big Beautiful Bill Act: What Practitioners Need to Know

L. Timothy Halleron focuses his practice on high-net-worth tax and estate planning matters. Tim advises individuals and family offices in planning for the preservation and transfer of wealth within families without the imposition of gift, estate or generation-skipping transfer tax.

Tim’s practice includes:

• Advising on design and drafting of estate planning documents, including wills, revocable and irrevocable trusts (including charitable trusts), family limited partnerships, shareholder agreements, and intra-family sale agreements
• Pre-liquidity event tax planning, including leveraged sales of interests in private companies to dynasty trusts, transfers to grantor retained annuity trusts, and pre- and post-sale charitable planning
• Advising on investment diversification, asset protection, and corporate and family governance issues, including the reorganization of private companies to improve the tax efficiency of those organizations
• Counseling on the formation and administration of a variety of tax-exempt and charitable entities
• Transfer situs of trusts to more favorable jurisdictions to take advantage of tax efficiencies and modernized trust laws, and advise clients with respect to state fiduciary income tax issues
• Structuring and implementing judicial and non-judicial modifications of irrevocable trusts
• Advising on the structuring and formation of private trust companies in various jurisdictions
• Preparing and reviewing estate and gift tax returns, including complex reporting and valuation issues, and negotiate settlements with the IRS on audited estate and gift tax returns
• Advising on litigation disputes between trustees and beneficiaries and in contested trust and tax matters, and consult with fiduciaries in probate and trust administration

Tim is a fellow of the American College of Trust and Estate Counsel (“ACTEC”), and Tim frequently writes and speaks on a variety of tax and estate planning subjects.

Sarah advises high-net-worth clients on a broad range of testamentary and inter vivos estate planning matters. She has extensive experience drafting and customizing wills, revocable trusts and irrevocable trusts. She is fluent in the administration of complex estate planning strategies including GRATs, CLATs, QPRTs, installment sales, intra-family loans, closely-held companies, charitable vehicles and leveraging techniques. She excels at designing transactions with unique assets or to accomplish specific planning objectives. Sarah also has experience administering large and complex estates and trusts.

Sarah enjoys working with numbers and using financial models and tax projections to guide clients in their planning. She develops complex models to project the impact of wealth transfer transactions, or assess the interaction between clients’ balance sheets and their estate plans. She uses those models to spot issues that may arise during the administration phase, such as liquidity shortages, and devises and implements solutions to those problems.

Sarah distills complex transactions and concepts into simple terms, and explains them to clients in summary fashion, whether through graphics, diagrams or bullet points.

Sarah is highly approachable and adept at developing relationships with clients of all ages and backgrounds. She is well-suited to advise multi-generational families, and particularly enjoys educating younger family members about estate and asset protection planning. Sarah regularly prepares premarital agreements and advises on other family law matters that may intersect with a client’s estate planning.

While in law school, Sarah was awarded the Edward H. McDermott Scholarship. She was president and founder of the Real Property/Trust & Estates Club. She was also a co-chair of the Northwestern Student Bar Association Admissions Committee and a member of the Northwestern Journal of Law and Social Policy.