Step Transaction Doctrine

Donald P. DiCarlo, Jr. (attorney, Villanova, PA) recently published his article entitled What Estate Planners Need to Know About the Step Transaction Doctrine, 45 Real Prop., Trust & Estate L.J. 355 (Summer 2010). An excerpt from the introduction is below:

This Article introduces (or reacquaints, as the case may be) estate planners to the basic theory of the step transaction doctrine and its development and application in estate planning techniques. This Article will also examine recent case law to identify methods that estate planners can use to avoid stepping on the issue with the Service, particularly regarding the use of LLCs as wealth transfer vehicles.