First and foremost, I consider myself a teacher. Tax and estate planning are complicated. I enjoy making these topics as simple as possible so my clients can be confident they are making the best decisions for themselves, their families, and the charities they care about.
I begin every relationship by helping families articulate their goals. Are there issues that need to be addressed? Are there opportunities to take advantage of? We then find solutions that balance tax optimization, complexity, risk, and competing non-tax interests.
I was previously a partner at Withers Bergman LLP and ArentFox Schiff LLP. I also spent seven years working as a strategist at two leading financial services firms. I use that unique background to engage a family's team of advisors, so we can fully integrate their personal, financial, and legal planning.
My practice focuses on the needs of wealthy individuals and families, their businesses, and charities. My experience includes domestic and international trust and estate planning, tax minimization, advanced life insurance strategies, and planned charitable giving.
I have helped clients with pre-sale and pre-IPO planning, planning with concentrated stock positions, planning with fund interests, trust decanting and modification, minimizing state income taxation of trusts, dynasty trusts, generation skipping transfer (GST) tax, split-dollar life insurance, planning with art, private foundations, charitable lead trusts, and charitable remainder trusts. I have advised families on the formation and operation of foreign trusts, pre-migration planning, foreign investment in U.S. real property, voluntary disclosures, and expatriation.
I have authored or co-authored more than 40 articles, and spoken at numerous industry conferences in the United States and globally. I previously chaired the Estate and Gift Tax Committee of the Real Property, Trust & Estate Section of the American Bar Association, and currently serve as Vice-Chair of the Income and Transfer Tax Committee of the RPTE Section of the ABA. My mother is very proud.
I grew up on Long Island, but currently live in Connecticut with my wife, our two daughters, and one very lazy dog.
American Bar Association, Real Property, Trust and Estate Law Section
- Chair RPTE Income and Transfer Tax Planning Group, September 2023-Present
- Vice-Chair RPTE Income and Transfer Tax Planning Group, September 2021-August 2023
- Chair RPTE Estate & Gift Tax Committee, September 2019-August 2021
- Vice-Chair RPTE Estate & Gift Tax Committee, September 2016-August 2019
- Member RPTE Continuing Legal Education Committee, September 2016-Present
- Member Trusts and Estates E-CLE Committee, August 2017-Present
- Member National CLE Meeting Committee, October 2018-Present
Congregation Beth Shalom Rodfe Zedek, Board Member 2021- Present
Chambers High Net Worth, Private Wealth Law - New York 2022 and 2023
Elected as a Fellow of the American College of Trust and Estate Counsel (ACTEC) 2023
Best Lawyers in America 2023
Peer Reviewed AV® Preeminent™, Martindale-Hubbell (2019)
In 2021 Stephen was named a “Go-To Thought Leader” and recognized with the COVID Legislation Estates & Trusts Impact award by the National Law Review for his article, “Estate Tax and the Build Back Better Act: Threats and Opportunities Before Year End."
State of Connecticut, 2001
State of New York, 2001
State of New Jersey, 2021
US Tax Court
New York University, LLM
Georgetown University Law Center, JD,, cum laude
Vassar College, BA, History and Africana Studies, double major
American Bar Association
Connecticut Bar Association
New York Bar Association
Contributions to the Field
- “The Corporate Transparency Act: Our new Normal”, Corporate Counsel Review, Volume 42, May 2023.
- Author, “Court Provides Relief For Those With a Second Home in New York”, National Law Review, February 2023.
- Author, “The Corporate Transparency Act: Our New Normal”, Trusts & Estates Magazine, January 2023.
- Co-Author, “Taxation of Non-Grantor Trusts”, Estate Planning, December 2022.
- Author, “New Corporate Transparency Regs Require US Beneficiary Registration”, Wealthmanagement.com, October 4, 2022.
- Author, “Being a New York Income Tax Resident: Did ‘Matter of Obus' Change the Game?”, New York Law Journal, September 9, 2022.
- Co-Author, “Insurance Trusts and GST- A Primer”, Estate Planning, November 2021.
- “Estate Tax and the Build Back Better Act: Threats and Opportunities Before Year End”, Schiff Hardin Alert, September 14, 2021, republished by Wealthmanagement.com.
- Co-Author, “New York Simplifies Power of Attorney Form”, WealthManagement.com, December 21, 2020.
- Author, “Election 2020: Will Estate Planning Ever be the Same?”, The New York Law Journal, September 11, 2020.
- Co-Author, “New York Allows Video Notarization for Estate Planning”, WealthManagement.com, March 24, 2020.
- Author, “Section 199A- The Great Divide”, Leimberg Income Tax Planning Newsletter #129, January 2018.
- Author, “Drafting Do's and Don'ts”, Probate & Property, column published between September/October 2017 and November/December 2018
- Co-Author, “2801: What U.S. Estate Planners Need to Know,” Trusts & Estates Magazine, November, 2016.
- Author, “2801- What Foreign Trustees Need to Do Now,” Offshore Investment, June, 2016.
- Primary author of “Expatriation and the New Section 2801 Proposed Regulations,” Heckerling White Paper of the International Tax Planning Committee of the Income and Transfer Tax Planning Group of ABA RPTE, January 2016.
- Author, “The Long Arm of US Tax Residence,” Offshore Investment, September 2015.
- Author, “Using DINGs to Reduce Federal Income Tax,” Trusts & Estates Magazine, July 2015.
- Author, “The Benefits and Burdens of Foreign Trusts,” Probate & Property, May/June, 2015.
- Co-Author, “Expatriation: Opportunities in a Mist of Uncertainty,” Journal of International Taxation, December 2014.
- Author, “Rethinking the Use of 529 Accounts for Funding College Costs,” Estate Planning, August 2013.
- Author, “Looking Back at the Cliff,” Offshore Investment, February 2013.
- Author, “Wandry Does Wonders for Formula Clause Gift Strategy,” Estate Planning, October 2012.
- Author, “Substantiation is Key to Charitable Contribution Deduction,” Estate Planning, September 2012.
- Author, "In Estate of Duncan, the Tax Court Returns to Traditional Graegin Loan Principals," Journal of Taxation, April 2012.
- Author, "Foundations for Fund Principals," Private Wealth, March/April 2012.
- Author, "IRS Issues Draft Form 8938 Instructions," Trusts & Estates Wealth Watch, October 2011.
- Author, "Owning US Real Estate: Depressed US Real Estate Yields a Rare Second Chance at Proper Structuring," Offshore Investment, October 2011.
- Author, "Oh my God! You're an American!" STEP Journal, May 2011.
- Author, "Valuation Clauses: Panacea or Pandora's Box?" Trusts & Estates Magazine, April 2011.
- Author, "Coming Clean - The US Voluntary Disclosure Initiative in Perspective," Offshore Investment, April 2011.
- Author, "Maybe Price is Right: Making Annual Exclusion Gifts of Non-Controlling Interests," Practical Tax Strategies, July 2010.
- Author, "Estate of Black: When is it ‘Necessary' to Pay Estate Taxes With Borrowed Funds?" Journal of Taxation, June 2010.
- Author, "HEART-ache: Expatriation Under the New Inheritance Tax," Estate Planning, April 2010.
- Author, "Efficient Gifting: Trusts and Tax-Advantaged Accounts are Powerful Tools for Gifting to Children," Private Wealth, March/April 2010.
- Author, "Cross Border Philanthropy: Why is Doing the Right Thing Never Easy?" STEP U.S.A. Issue 10, November 2009.
- Co-Author, "Giving to Greece: The Challenge of Cross-Border Philanthropy," Odyssey, May/June 2009.
- Author, "Fractional Interest Gifts of Art-Back to Stay or Going Away?" Taxation of Exempts, September/October 2008.
- Author, "Striving for Certainty: How to use valuation clauses when transferring hard-to-value assets," Private Wealth, August 2008.
- Author, "Crossing the Generational Divide," Private Wealth, November 2007.
- Co-Author, "Charitable Lead Annuity Trusts-A Primer," Taxation of Exempts, July/August 2007.
- Co-Author, "Defining Trust Income," Trusts and Estates Magazine, May 2005.
- “Breaking Old Habits: Revisiting Tax Driven Restrictions When Naming a Trustee”, Notre Dame Tax & Estate Planning Institute, September 22, 2023.
- “The Corporate Transparency Act: What Estate Planners Need to Know”, New York State Bar Association webinar, July 18, 2023.
- "Identifying Beneficial Owners under the Corporate Transparency Act,” 35th Annual RPTE National CLE Conference, Washington DC, May 2023.
- "Annual Exclusion Planning with Grandchildren,” 35th Annual RPTE National CLE Conference, Washington DC, May 2023.
- “Highlights of the 2023 Heckerling Institute on Estate Planning,” Estate Planning Council of New York City, March 14, 2023.
- “Successor Trustees and Section 672(c)”, ABA Tax Section Midyear Meeting, February 10, 2023.
- “The Corporate Transparency Act: Our New Normal”, Trusts & Estates Virtual Forum, February 7, 2023.
- “Highlights of the 2023 Heckerling Institute on Estate Planning”, Trusts & Estates Virtual Forum, February 1, 2023.
- “The Generation Skipping Transfer Tax: Key Concepts and Common Reporting Issues”, New York State Society of CPAs Private Wealth Conference, December 7, 2022.
- “Drafting Trusts: Learning From the Mistakes of Others”, Wealth Counsel, July 21, 2022.
- “Planning for Expatriation”, PLI International Estate & Tax Planning 2022, June 1, 2022.
- “Corporate Transparency Act- Welcome to the Future”, ABA RPTE National CLE Conference, April 28, 2022.
- “Reducing Estate Tax: Strategies Every Planner Needs to Know”, Wealth Counsel Webinar, February 8, 2022.
- “Fundamentals of International Estate Planning”, New York State Society of Certified Public Accountants Estate Planning Conference, October 28, 2021.
- “Year End 2021: Here We Go Again”, ABA RPTE Webinar, September 14 2021.
- “The Generation Skipping Transfer Tax: Beyond the Basics”, Wealth Counsel Webinar, September 1, 2021.
- Moderator, “Canadian Tax Traps for the Unwary American”, ABA RPTE E-CLE, July 20, 2021.
- “The Defined Value Clause – No Longer Exotic”, ABA RPTE National CLE Conference, April 2021.
- “Successor Trustees and Section 672(c): A Prison of Our Own Making?”, ABA RPTE National CLE Conference, April 2021.
- “Fitting Yesterday's Trusts to Today's Needs: Ongoing Administration for Long-Term Vehicles”, Estate Planning Council of New York, January 28, 2021.
- Moderator, “Valuation in the Time of Covid: Where Are We Now?”, ABA RPTE E-CLE, December 15, 2020.
- Moderator, “Paying For Life Insurance- When the premiums get big, it ain't so easy”, ABA RPTE National CLE Conference, May 2020.
- “Ten Things I Hate About U…TC”, ABA RPTE National CLE Conference, May 2020.
- “Unwinding and Exiting Family Limited Partnerships and LLCs”, 57th Great Plains Federal Tax Institute, December, 2019.
- Moderator, “The Qualified Business Income Deduction for Real Estate Investors and Professionals”, ABA RPTE Spring Symposia, May 2019.
- Moderator, “Universal Life Insurance”, ABA RPTE Spring Symposia, May 2019.
- “Everything Old is New Again: Forming a Family Business After the TCJA”, 56th Great Plains Federal Tax Institute, November, 2018.
- “Expatriation: What You'll Pay When There's Nothing Left to Say”, 21st International Tax Symposium, State Bar of Texas, November, 2018.
- “The Forgotten Transfer Tax: The Fundamentals of the Generation Skipping Transfer Tax”, ABA RPTE E-CLE Webinar, September 2018.
- “Inter-generational Split Dollar Insurance Arrangements After Cahill and Morrissette: Avoiding Revaluation Issues”, Strafford Publications Webinar, September 2018.
- “Powell Proof Your Partnership”, ABA RPTE Spring Symposia, May 2018.
- “Drafting Do's and Don'ts: Small Errors and a World of Problems”, ABA RPTE Spring Symposia, May 2018.
- “Moving to Tax Paradise: Three Options for the Mobile Taxpayer”, ABA Joint Fall CLE Meeting, September 2017.
- “Elevate Your Drafting,” ABA RPTE Spring Symposia, April 2017.
- “The Bad and the Ugly of Trust Drafting,” Federal Tax Institute of New England, November, 2016.
- “Avoiding International Entanglements for the Domestic Estate Planning Attorney,” ABA RPTE Spring Symposia, May 2016.
- “Section 2801 Uncovered: Taxation of Gifts and Bequests from Covered Expatriates,” ABA Joint Fall CLE Meeting, September 2015.
- “Gift Tax Treatment of High Interest Rate Loans,” ABA RPTE Spring Symposia, May 2015.
- “Foreign Trust Traps: In-Bound Planning With Foreign Trusts,” ABA Joint Tax and RPTE Fall Meeting, September 2014.
- “Expatriation,” 21st World Offshore Convention, New York, NY, October 2014.
- “US Beneficiaries of Foreign Trusts and Foreign Beneficiaries of US Trusts: A Primer for Domestic Planners,” ABA RPTE Spring Symposia, May 2014.
- “Planning for Tentative & Reluctant Clients,” Estate Planning Council of Suburban Maryland, December 2013.
- “After Wandry: Planning With Defined Value Clauses,” Internal Training Session for Holland & Knight LLP, November 2013.
- “Expatriation,” 20th World Offshore Convention, New York, NY, November 2013.
- “The Art of Fiduciary Selection,” Barclays External Presentation, Boca Raton, October 2013.
- “Delaware Incomplete Gift Non-Grantor (DING) Trusts,” Barclays External Presentation, Palm Beach and Boca Raton, October 2013.
- “Expatriation Under Section 877A and 2801,” Chicago Bar Association Asset Protection Committee, October 2013.
- Panelist, “How Has Asset Management and Estate Planning Evolved in an Era of Increased Tax Transparency?” FIBA Wealth Management Forum, Miami, September 2013.
- “The Use of Credit in Estate Planning,” Boston Estate Planning Council, December 2012.
- “Voluntary Disclosure and Reporting Obligations,” 19th World Offshore Convention, Puerto Rico, November 2012.
- "Tax and Reporting Obligations of US Green Card Holders," STEP Johannesburg, South Africa, May 2010.
- "Governance and Legal Framework for Private Social Investment," IDIS/CAF Foundation School, Sao Paulo, Brazil, October 2008.
- "US Tax Planning Strategies for the International Family," August 2008.
- "The Tools and Techniques for Effective Business Succession Planning," February 2008.
- "Estate Planning for Blended and Extended Families," at the 4th Annual Conference of the Association of Divorce Financial Planners, September 2006.
- "Installment Sales to Defective Trusts, Dispelling the Myths, Spelling Out the Opportunities," presented by Withers Bergman LLP, Connecticut, November and January 2004.
- "How to Protect Assets During Life and Avoid Estate Tax at Death in Connecticut Use of Family Limited Partnerships in Estate Planning," sponsored by NBI, Inc., Connecticut, September 2003.