Extract to table

Any such discounts must be supportable upon examination by the Internal Revenue Service

Caldwell and the Calderwood & Harkness LLP planning team have identified the following additional concerns and special considerations that must be addressed in the design and implementation of the estate plan: 1

The estate plans of both spouses must be coordinated to ensure consistency, avoid duplication, and maximize the aggregate use of both spouses' estate and gift tax exemptions

The carried-interest and LP positions in the Caldwell Ridgeline Capital funds must be reviewed to confirm that they can be validly assigned to GRATs and other estate planning vehicles

Transfer restrictions in the fund limited partnership agreements, including general partner consent requirements, rights of first refusal, and anti-assignment provisions, must be identified and addressed prior to funding

Any valuation discounts applied to the membership interest in Stonecrest Realty Holdings LLC or to the fund interests in the Caldwell Ridgeline Capital platform must be supportable upon examination by the Internal Revenue Service