INSTANT DOWNLOAD: “Defined Value Transactions – A 2-Part Program”

🚨 The IRS Is Watching! Are Your Defined Value Transfers Audit-Proof?

Master the Most Critical Estate Planning Tool You Might Be Using Incorrectly

Defined Value Transactions are one of the most powerful (yet most misunderstood) tools in the estate planner’s toolkit. With the Fifth Circuit’s affirmation in Nelson v. Commissioner, the margin for error just got smaller.

If you’re an attorney, CPA, or advisor working with high-net-worth clients, you can’t afford to miss this deep dive into the latest legal rulings, drafting strategies, and compliance pitfalls.

Learn from two of the foremost authorities on this subject and gain the clarity, tools, and confidence you need to protect your clients (and yourself). Nationally renowned CPA and tax expert, Robert S. Keebler, CPA/PFS, MST, AEP (Distinguished), and L. Paul Hood, Jr., JD, LL.M., have teamed up for this special 2-part presentation on Defined Value Transactions.

PART 1: “Those Ten Missing Words: Defined Value Gift/Sale Clauses After the Fifth Circuit Affirms Nelson”

In this 95-minute session, Bob Keebler and Paul Hood walk you through the critical legal landscape of defined value transfers — from Procter to Wandry to the recent Fifth Circuit Nelson decision — and help you avoid costly missteps when drafting or advising on these strategies.

You’ll learn:

✅ Which defined value strategies are still effective — and which ones put you (and your client) at risk. Cut through the clutter with Paul and Bob’s real-world analysis of what will withstand IRS scrutiny (and what won’t!)

✅ Why accurate and strategic reporting of defined value transfers is essential. Learn how small reporting missteps can undermine the entire transaction and how to get it right the first time.

✅ The key differences among the main types of defined formula value clauses. Understand which clause types to use in which situations, and the legal reasoning behind them.

✅ How to use formula allocation clauses based on post-transaction agreements. Discover how (and when) these flexible clauses can work — and the legal vulnerabilities they may present.

✅ When and how to use formula allocation clauses tied to final gift tax values. Learn how to align your documents with gift tax determinations to avoid unwanted IRS attention.

✅ Where price adjustment clauses still fit in your planning arsenal. A nuanced discussion of these older tools and whether they remain viable under current case law.

✅ The far-reaching implications of the Belk holding (4th Cir., 2014) for modern planning. See how this often-overlooked case may quietly limit certain clause structures (and how to adapt).

✅ The IRS’s stance on defined value clauses, including their appearance on the 2016–17 Priority Guidance Plan. Get inside the IRS’s radar and stay ahead of future developments.

✅ How to use substitution powers effectively with a defined value clause. Learn the right (and wrong) ways to pair this power with your planning strategy.

✅ Common traps and red flags to avoid when using defined value clauses. Prevent costly errors with Bob and Paul’s list of the most frequent drafting, execution, and reporting mistakes.

PART 2: “Drafting, Executing & Reporting Best Practices: A Practical Boot Camp for Estate Planners Who Want to Get It Right”

In this 92-minute intensive, Keebler and Hood roll up their sleeves and guide you clause-by-clause through what a bulletproof defined value transfer should look like (and why!). Ideal for attorneys, CPAs, and advisors who want to turn theory into confident action.

You’ll discover:

🧠 What a defined value clause actually is and why it matters more than ever. Go beyond surface-level definitions to the strategic core of what makes these clauses work.

🎯 Why the real goal of defined value planning is tax efficiency, not charity. Explore the ethical and strategic boundaries of using valuation formulas (and what courts are really looking for).

📘 How the Internal Revenue Code and Treasury Regulations expressly authorize formula clauses (if done correctly). Learn how to align your planning techniques with black-letter law for greater defensibility.

🔎 A side-by-side comparison of the main types of defined value clauses. Understand the key differences, ideal use cases, and drafting considerations for each.

💼 Step-by-step best practices for implementing Wandry-type transactions. From structure to substantiation, learn how to make these strategies work in today’s IRS environment.

❤️ Special considerations and suggested steps for transactions involving charitable organizations. Don’t overlook the unique reporting, valuation, and compliance considerations when charities are involved.

These sessions aren’t just theory — they’re a practical masterclass in how to use defined value transfers confidently, legally, and effectively. Ideal for estate planners, CPAs, and financial advisors working with high-net-worth clients or complex estates.

Your purchase includes an instantly accessible MP4 video and audio recording, along with PDF handout materials. You get all of this and more for you and your office for just $249. A PDF transcript is available as an add-on for an additional fee.

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