Carmen Irizarry-Díaz

Shareholder
McLean,  VA  U.S.A.
Phone703.903.7511

Peer Rating
 5.0/5.0
AV® Preeminent

Client Rating

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Practice Areas

  • Tax
  • Estate Planning
  • Tax & Business Group
  • Insurance Regulatory & Transactions
 
Contact InfoTelephone: 703.903.7511
Fax: 703.749.1301
http://www.gtlaw.com/People/Carmen-Irizarry-Diaz
 
University University of Puerto Rico College of Business Administration, B.B.A., Business Administration/Finance, magna cum laude
 
Law SchoolUniversity of Puerto Rico School of Law, J.D., magna cum laude; New York University, LL.M., Taxation
 
Admitted1982, Puerto Rico; 1984, District of Columbia; Virginia
 
Memberships 

Professional & Community Involvement

•Member, American Bar Association, Sections of Taxation and Real Property, Probate and Trust
•Member, District of Columbia Bar Association
•Member, District of Columbia Estate Planning Council
•Member, Hispanic Bar Association of the District of Columbia
•Member, International Bar Association
•Member, National Hispanic Bar Association
•Member, Puerto Rico Bar Association
•Member, Society of Trust and Estate Practitioners (STEP)
•Member, Virginia State Bar Association
•Past Chair of the Subcommittee on Reporting Requirements and Gift Tax of the American Bar Association Section's Estate and Gift Taxes Committee

 
LanguagesPortuguese, Conversational; Spanish
 
BornPuerto Rico, 1956
 
Biography

Carmen Irizarry-Diaz focuses her practice on sophisticated income, gift, estate, charitable, and business preservation and succession planning for U.S. and international individuals and families. She has experience in the tax reporting and disclosure of transactions, as well as representing clients before the Internal Revenue Service (IRS) and other tax authorities.

Prior to joining the firm, she served as Attorney-Advisor to Judge Jules G. KOrner, III, of the United States Tax Court. She is a frequent speaker on estate planning topics and the author of many articles that have appeared in leading tax publications. As part of her practice, Carmen routinely structures transactions to meet clients' goals and achieve optimal tax results. She drafts implementing documents such as powers of attorney, advance medical directives, wills and revocable and irrevocable trusts, including credit shelter or exemption, pour over, disclaimer, generation-skipping transfer (GST), life insurance (ILIT), qualified domestic (QDOT), qualified terminable interest property (QTIP), qualified personal residence (QPRT), and grantor retained annuity trusts (GRAT). Carmen also probates estates and administers trusts, prepares gift and estate tax returns and advices on related issues.

Carmen's charitable planning practice encompasses the creation, administration, and dissolution of public charities, private foundations, and lifetime and testamentary charitable trusts, including grantor and non-grantor charitable lead annuity trusts (CLAT), charitable lead unitrusts (CLUT), charitable remainder annuity trusts (CRAT), and charitable remainder unitrusts (CRUT).

Areas of Concentration

•Complex domestic and international income, gift, and estate planning
•Business counseling, restructuring, and succession planning
•Sophisticated life insurance and premium-financing planning
•Charitable planning
•Nontraditional couples and families
•Estate and trust administration
•Post-mortem tax planning
•Federal and state gift and estate tax reporting

Awards & Recognition

•Rated, AV Preeminent 5.0 out of 5

AV, BV, AV Preeminent and BV Distinguished are registered certification marks of Reed Elsevier Properties Inc., used under in accordance with the Martindale-Hubbell certification procedures, standards and policies.

Articles, Publications, & Lectures

Articles
•Author, Rev. Rul. 2007-13: IRS Rules on Transfer for Value Aspect of Sales of Life Insurance Contracts to Grantor Trust, Management Memorandum Vol. 48, No. 14, Advisory Board Analysis, pp. 259-267, July 9, 2007
•Author, Should You Be Filing a Federal Gift Tax Return for Gifts Made in 2006? April 6, 2007
•Author, Should You Be Filing a Federal Gift Tax Return for Gifts You Made in 2005? April 10, 2006
•Author, Federal Estate Tax Exemption Amounts and Rates are Changing - So Do I Need to Change My Will? December 10, 2005
•Author, Tax Considerations in the Choice of Trustees, Tax Management Memorandum, Vol. 45. No. 15, Advisory Board Analysis, pp. 283-298, July 26, 2004
•Author, The Good News, Bad News of Changes to Federal Transfer Tax, New York Law Journal, March 1, 2004
•Author, Shifting Future for Estate Taxes, National Law Journal, March 1, 2004
•Author, Federal Estate Tax Exemption Amounts and Rates are Changing, January 13, 2004
•Author, Automatic Allocation of GST Exemption Rules in the Economic Growth and Tax Relief Reconciliation Act of 2001, April 28, 2002
•Author, Effective Use of the Election to Split Gifts, Tax Management Estate, Gifts and Trusts Journal, Vol. 26, No. 6, November 8, 2001
•Author, How Defective Is Your Trust? Suggestions on Structuring an Intentionally Defective Grantor Trust, Tax Management Memorandum, Vol. 41, No. 13, Advisory Board Analysis, pp. 231-243, June 19, 2000
•Author, Lifetime QTIP Trusts: A Valuable Estate Planning Tool, Tax Management Memorandum, Vol. 36, No. 14, pp. 203-208, July 10, 1995
•Author, Amortization of FCC Broadcast Licenses, Tax Management Memorandum, Vol. 34, No. 23, pp. 343-350, November 15, 1993
•Author, Final Partnership Disguised Sale Regulations Under Section 707(a)(2), Tax Management Memorandum, Vol. 34, No. 3, Advisory Board Analysis, pp. 31-42, February 8, 1993
•Author, Aizawa v. Comr., 99 T.C. No. 10 (8/6/92) - The 'Amount Realized' on the Foreclosure Sale of Property Subject to a Recourse Mortgage, Tax Management Memorandum, Vol. 33 No. 26, pp. 381-386, December 28, 1992
•Author, Creation of Section-456 At Risk Liability Through Sales and Leasebacks - Emershaw v. Commissioner, 949 F.2d 851 (6th Cir. 1991), Tax Management Memorandum, Vol. 33 No. 7, pp. 99-105, April 6, 1992

Lectures
•Co-Speaker, Teachings from the 43rd Annual Heckerling Institute on Estate Planning, National Capital Chapter of the Society of Financial Service Professionals, McLean, VA, February 10, 2009
•Speaker, Practical Gift-Tax Return Preparation, Montgomery County Bar Association, October 4, 2006

Previous Employment

•Attorney-Advisor, Honorable Jules G. KOrner III, United States Tax Court, 1984-1986
•Research assistant to Professor Charles Terry, New York University, Summer 1983
•Summer Intern, Securities and Exchange Commission, 1981 (Also at Washington, D.C. Office)

 
Reported CasesSignificant Representations: Assisted in restructuring stock ownership of closely-held businesses for purposes of gifting of minority interests, including federal and state government contractors, real estate developers, and technology companies.; Structured and funded dynastic trusts structured as grantor trusts with business interests and other assets.; Prepared and advised regarding numerous gift tax returns, related adequate disclosure statements and elections in and out of automatic generation-skipping tax exemption, and audits.; Assisted high-net worth family with core legacy plans for several generations of family members located in various estate in coordination with family's Family Office.; Assisted senior non-U.S. generation of international family comprised of U.S. and non-U.S. persons with core legacy plans and implementation and funding of foreign trusts.; Assisted dual nationals with disclosure of unreported foreign accounts to IRS.; Assisted non-traditional couples with gift and estate tax planning, retitling of assets, and property agreements.; Assisted with retirement planning for highly-compensated executives, including the implementation and funding of grantor charitable lead trusts in the year of retirement.; Structured and funded charitable remainder trusts, charitable lead trusts (both grantor and nongrantor), and private foundations (structured as trusts or corporations).; Structured irrevocable trusts funded with S corporation stock for which QSST or ESBT elections were filed to preserve S corporation status for business.; Assisted in filing of post-mortem qualified disclaimers by surviving spouses to allow full utilization of predeceased spouse's federal estate tax exemption.; Assisted in judicial and non-judicial appointments of trustee's appointment of trust property to second trust (decanting).; Assisted in the judicial and non-judicial reformation/modification of trusts.; Assisted in structuring and funding of several irrevocable trusts designed to avoid the application of the Florida intangibles tax to Florida residents.; Assisted in the administration of estates and funding of trusts, including obtaining appraisals for tangible and real property.; Prepared federal and estate tax returns for estates comprising assets in multiple jurisdictions.; Assisted in the structuring and funding of, managing annuity payments (including in further trust) from, and exercising powers of substitution with respect to, Grantor Retained Annuity Trusts (GRATs), for federal income and transfer-tax efficiency.; Assisted in the structuring and funding of Qualified Personal Trusts with interests in principal and vacation homes, including obtaining appraisals, preparation of post-retained interest term lease agreements, and related gift-tax reporting.; Assisted with Qualified Domestic Trust planning for non-U.S. citizen spouse.; Counseled personal representative/surviving spouse of non-US citizen deceased spouse regarding availability of deceased spousal unused exclusion amount (DSUEA) and related federal estate tax return preparation issues.; Structured and implemented irrevocable life insurance trusts and policy premium-financing agreements.; Assisted in the severance of trusts into GST exempt and non-exempt trusts.; Assisted in the late allocation of GST exemption to dynasty trusts.
 
ISLN906251353
 


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Office Information

Carmen Irizarry-Díaz

1750 Tysons Boulevard, Suite 1200
McLeanVA 22102




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