EVENT DESCRIPTION
Give CPAs a working command of the Section 453 installment method as a transaction-design tool, the published authority that supports a substitute-obligor structure, the economics of an 8.5% coupon on gross (pre-tax) proceeds, and the role of a life-insurance wrapper in hedging the tax that comes due at the end of the deferral.
EVENT OBJECTIVE
Provide working knowledge to attendees on:
• How to have a 453 (Deferred Installment Method)-transaction structured properly before contracts are executed or in LOI phase.
• Why "Stock" sales setup more favorably than "Asset" sales.
• Why the economics of a Sec 453 structured transaction makes the most sense.
• How Sec 453 can be a more effective alternative than 1031-exchange for the sale of Real Estate.
• How 453-structured transactions provides a means to accomplish tax reduction in addition to tax deferral.
• How 453 creates a forecastable and stabilized income stream that also provides for the Client's estate postmortem.
