Patrick J. Saccogna

About Patrick J. Saccogna

Patrick works in the Personal & Succession Planning practice group of the law firm of…

Experience

1. Senior Counsel

   Thompson Hine LLP

   Aug 2002 — Present · Cleveland/Akron, OH, US

   I have expertise in Trusts and Estates, including the following representative matters:Implemented tax free \"Rounds 2 and 3\" grantor trust installment sales transactions to facilitate senior family member\'s transfer of additional S corporation stock to dynastic trusts for the benefit of future generations;Defended and negotiated the settlement of a two and one-half year federal gift tax audit of matriarch with gift tax exposure exceeding $1 million;Designed GST tax exempt posterity trusts to hold voting control of family owned businesses, assure continuity of asset management, and facilitate estate, gift, and GST tax valuation objectives;Advised on the income, gift, estate, and GST tax consequences of a partnership arrangement involving a QTIP trust to allow payment of estate tax on a Graegin type installment basis;Implemented a variety of family partnerships, stock recapitalizations, intra family installment sales to grantor trusts, Grantor Retained Annuity Trusts (GRATs), and other estate freeze techniques to accomplish family business, wealth transfer, and investment objectives;Formulated Charitable Remainder Trusts and Charitable Lead Trusts to facilitate charitable planning objectives, including counseling on the pre-funding split and merger of strategically located real estate in connection with a \"FLIP\"/NIMCRUT type of Charitable Remainder Trust; Counseled fiduciary on the grantor\'s repurchase of GRAT-owned shares of stock in a rapidly appreciating company thereby locking in a substantial transfer tax-free remainder distribution to grantor\'s children;Provide advice to a large family office with respect to myriad of multi-generational estate, gift, GST, and income tax and business succession planning issues; andQuarterbacked several \"bailout\" transactions involving defective Irrevocable Life Insurance Trusts, including the design and implementation of tax free trust-to-trust grantor trust sales transactions.

Education

• Case Western Reserve University School of Law

  J.D., magna cum laude, Law

  1987 — 1990

• Case Western Reserve University School of Law

  LL.M., Law (Taxation)

  1995 — 1999

• Kent State University

  B.B.A., summa cum laude, Accounting

  1983 — 1987

Skills

• Estate Tax Planning
• Accounting
• Legal Writing
• Estate Law
• Cpa
• Financial Planning
• Wills
• Tax
• Trusts
• Retirement Planning
• Estate Administration
• Conference Speaking
• Powers of Attorney
• Llc
• Wealth
• Appeals
• Succession Planning
• Estate Planning
• Public Speaking
• Tax Law
• Gift Tax
• Income Tax
• Financial Planners