Tye designs estate plans which allow high-net-worth individuals to leverage use of their gift, estate and generation-skipping transfer tax (GST) exemptions and to pass wealth to the next generation in a way that is both tax-efficient and creditor-protected. He implements sales to grantor trusts, grantor retained annuity trusts (GRATs), charitable lead and remainder trusts and business entities designed to achieve his clients' nontax and potentially tax objectives.
Tye advises principals in private equity, venture capital and hedge funds regarding strategies for transferring their fund interests to minimize the impact of estate, gift and GST taxes. He advises business owners on business succession planning and leverages an array of asset protection techniques. Tye counsels farmers, business owners and art collectors on strategies for handling illiquid assets, including the use of Graegin loans and qualifying for the benefits of Code Sections 2032A and 6166. He also represents fiduciaries in the administration of estates and trusts, the formation and operation of private foundations and sophisticated charitable giving techniques.