SPACs and Estate Planning: Transfer Planning for SPAC Assets, Income and Gift Tax Planning, Pitfalls to Avoid

Course Details
- smart_display Format
On-Demand
- signal_cellular_alt Difficulty Level
- work Practice Area
Estate Planning
- event Date
Tuesday, August 31, 2021
- schedule Time
1:00 p.m. ET./10:00 a.m. PT
- timer Program Length
90 minutes
-
This 90-minute webinar is eligible in most states for 1.5 CLE credits.
This CLE course will provide trust and estates counsel an in-depth analysis of key planning techniques for special purpose acquisition company (SPAC) shares and assets. The panel will provide common structures and transactions of SPACs, types of SPAC assets, and their wealth transfer planning opportunities. The panel will also offer techniques for shifting SPAC assets and future appreciation out of the taxable estate and strategies for navigating complex tax issues for gift planning with SPAC assets.
Faculty

With more than 30 years of experience, Mr. Lipoff specializes in the delivery of domestic and international private client services to enable high-net-worth individuals and families to maximize their new or generational wealth. He provides strategic advice to his clients and their closely held businesses in the areas of income tax planning and compliance, estate planning and administration services, as well as family structure consulting. Through many years in practice, he synthesized the work of various related professionals, and their firms integrate several planning strategies into solutions that maximize value. Mr. Lipoff is a frequent lecturer and author of articles published through professional forums on topics including domestic and international - estate planning and fiduciary income taxation including constructive attribution rules for foreign trusts, Forms 3520 & 3520-A, Graegin Loans, business succession, generation-skipping transfers, Chapter 14 and carried interest estate planning for private investment fund principals, preferred freeze partnerships, and private placement life insurance.

Mr. Geyer is a Managing Director in the firm’s Valuation Advisory group. He has completed hundreds of valuations of companies ranging in size from pre-revenue to over $10 billion in annual revenue. Mr. Geyer's extensive experience covers a broad and diverse range of valuation assignments for purposes that include estate and gift tax, transaction fairness, and litigation, as well as corporate and personal income tax. He oversees Stout’s Northern California operations.

Description
SPACs have recently gained greater popularity presenting unique estate planning opportunities for members of the sponsor entity and investors. Estate planners must identify key planning opportunities for sponsors and investors of SPACs and pitfalls to avoid under current tax law.
A SPAC is a special purpose acquisition company that raises capital in the public markets via an initial public offering to acquire a private company. They are commonly referred to as "blank-check companies" because an acquisition target has not been identified at the time of the IPO. Due to their speculative nature, the value of SPAC interests can grow substantially over time, providing wealth transfer opportunities via gifting, use of trusts, and other techniques.
Estate planners must recognize key issues under current tax law, valuation considerations, issues for gifts of interests, and other items impacting estate planning for SPAC assets.
Listen as our panel discusses common structures and transactions of SPACs, types of SPAC assets, techniques for shifting SPAC assets and future appreciation out of the taxable estate, and navigating complex tax issues for gift planning.
Outline
- Overview of SPAC assets and structures
- Planning for SPAC sponsors and investors
- Carried interest and SPACs
- Valuation issues
- Tax complexities of SPAC assets
Benefits
The panel will review these and other key issues:
- What are the common structures and transactions of SPACs?
- What are the types of SPAC assets and their wealth transfer planning opportunities?
- How can you shift SPAC assets and future appreciation out of the taxable estate?
- What strategies are available for minimizing tax issues for gifting SPAC assets?
Related Courses

Beneficiary Deemed Owner Trusts Under IRC 678(a)(1): Using BDOTs for Income Tax Savings and Simplification
Wednesday, April 2, 2025
1:00 p.m. ET./10:00 a.m. PT

Estate Planning for Business Owners: Buy-Sell Agreements, Non-Family Interests, Valuation Considerations, Tax Issues
Wednesday, April 2, 2025
1:00 p.m. ET./10:00 a.m. PT
Recommended Resources
Building Your Book: Strategies to Secure Long-Term Success
- Business & Professional Skills
- Career Advancement
- Talent Development