Diana S.C. Zeydel: Lawyer with Greenberg Traurig, LLP

Diana S.C. Zeydel

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Chair, Trusts & Estates Practice
Miami,  FL  U.S.A.
Phone305.579.0575

Peer Rating
 5.0/5.0
AV® Preeminent

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Practice Areas

  • Tax
  • Wealth Management
  • Trusts & Estates
 
Contact InfoTelephone: 305.579.0575
Fax: 305.579.0717
http://www.gtlaw.com/People/Diana-S-C-Zeydel
 
University Yale University, B.A., summa cum laude, 1982 Elected to Phi Beta Kappa
 
Law SchoolYale Law School, J.D., 1986; New York University School of Law, LL.M., 1993
 
Admitted1987, New York; 1995, Florida; Alaska
 
Memberships American Bar Association (Member, Committee on Governmental Submissions, 2007-present; Co-Chair, Generation-Skipping Tax Committee of the Real Property, Probate and Trust Law Section, 2001-2007); The Florida Bar (Member, Trust Law Committee, 1997-present, past Vice Chair; Member, Estate and Trust Tax Planning Committee, 2009-present; Member, Executive Council, 1997-2007).
 
Born1956
 
Biography

Diana S.C. Zeydel focuses her practice on estate, trust and tax planning for high net worth individuals and families. Her practice includes planning for U.S. and non-U.S. citizens and residents. She specializes in sophisticated intra-generational wealth transfer strategies and business succession planning. She assists clients in litigated probate, trust and guardianship matters, and represents clients before the Internal Revenue Service in matters involving complex fiduciary income tax and estate, gift and generation-skipping transfer tax matters. Diana has particular experience planning with life insurance and retirement assets. She also represents corporate and individual fiduciaries in connection with the administration of estates and personal and charitable trusts. Diana has represented clients in preparing prenuptial and postnuptial agreements. She has participated in numerous projects involving governmental submissions in the estate, gift and GST tax areas, and has begun serving as an expert witness in matters involving her areas of expertise.

Diana is a frequent lecturer and author and has spoken on a variety of topics before the American College of Trust and Estate Counsel, the Real Property, Trust and Estate Section of the American Bar Association, the Real Property, Probate and Trust Law Section of the Florida Bar, as well as various other professional organizations.

Prior to attending college and law school, Diana was a professional ballet dancer. She received her training on a full scholarship at the Joffrey Ballet School in New York, and was awarded an apprenticeship with the Company. She instead accepted an offer to join the Chicago Ballet, where she was quickly given the opportunity to perform soloist and principal roles.

Areas of Concentration

· Multi-generational wealth transfer planning

· Business succession planning

· International estate and pre-immigration planning

· Estate, trust and guardianship administration and controversies

· Estate, gift and generation-skipping tax controversies

· Prenuptial and postnuptial agreements

Professional & Community Involvement

· Academician, The International Academy of Estate and Trust Law

· American College of Trust and Estate Counsel (ACTEC)
- Regent
- Chair, Estate and Gift Tax Committee, 2009-2012; Member, 2005-2012
- Member, International Estate Planning Committee, 2005-present
- Member, Fiduciary Income Tax Committee, 2007-present
- Member, Program Committee, 2002-2004, 2009-2011
- Member, Nominating Committee, 2001-2002

· American Bar Association (ABA)
- Member, Committee on Governmental Submissions, 2007-present
- Co-Chair, Generation-Skipping Tax Committee of the Real Property, Probate and Trust Law Section, 2001-2007

· The Florida Bar
- Member, Trust Law Committee, 1997-present (past Vice Chair)
- Member, Estate and Trust Tax Planning Committee, 2009-present
- Member, Executive Council, 1997-2007

· Miami City Ballet
- Member, Community Development Board

Awards & Recognition

· Listed, The Best Lawyers in America, Litigation - Trusts and Estates; Tax Law; Trust and Estates, 2008-2014

· Listed, Chambers USA Guide, ranked nationally and in Florida, 2007-Present

· Listed, Super Lawyers magazine, Florida Super Lawyers, 2006-2013

· Listed, Euromoney Institutional Investor's Expert Guides, "Guide to the World's Leading Women in Business Law," 2012

· Nominated, Chambers USA Women in Law Award in Wealth Management, 2012

· Listed, Florida Trend magazine "Legal Elite," Tax Law, 2011

· Recommended, PLC Which Lawyer?, 2009

· Winner, South Florida Business Journal "Key Partner Award," Legal-Tax category, 2008

· Rated, AV Preeminent® 5.0 out of 5

Publications & Presentations

Articles, Lectures & Publications

Articles

· Co-Author, "Portability or No: The Death of the Credit-Shelter Trust," Journal of Taxation, May 2013

· Co-Author, "Imposition of the 3.8% Medicare Tax on Estates and Trusts," Estate Planning, April 2013

· Co-Author, "Congress Finally gives Us a Permanent Estate Tax Law," Journal of Taxation, February 2013

· Co-Author, "New Portability Temp. Regs. Ease Burden on Small Estates, Offer Planning for Large Ones," Journal of Taxation, October 2012

· Author, "When Is a Gift to a Trust Complete: Did CCA 201208026 Get It Right?" Journal of Taxation, September 2012

· Co-Author, "Turner II and Family Partnerships: Avoiding Problems and Securing Opportunity," Journal of Taxation, July 2012

· Co-Author, "An Analysis of the Tax Effects of Decanting," Real Property, Trust and Estate Law Journal, Spring 2012

· Author, "Developing Law on Changing Irrevocable Trusts: Staying Out of the Danger Zone," Real Property, Trust and Estate Law Journal, Spring 2012

· Principal Author of the Comments submitted by ACTEC in response to Notice 2011-101 on "Transfers by a Trustee from an Irrevocable Trust to Another Irrevocable Trust (Sometimes called "Decanting")," April 2012

· Contributor to the Comments submitted by ACTEC in response to Notice 2011-82 on "Guidance on Electing Portability of Deceased Spousal Unused Exclusion Amount," October 2011

· Co-Author, "A Practical Guide to Estate Planning," Chapter 2 Irrevocable Trusts, Section V. Estate Planning Tools that are Inter Vivos in Nature, 2011

· Co-Author, "Estate Planning After the 2010 Tax Relief Act: Big Changes, But Still No Certainty," Journal of Taxation, February 2011

· Co-Author, "A Walk Through the Authorities on Formula Clauses," Estate Planning, December 2010

· Co-Author with Elina Todorova, "Making Gifts to Minor Grandchildren in 2010 --Can It Be Done?," BNATAX Management, December 2010

· Author, "A Phantom Estate Tax," Private Wealth, May, June 2010

· Co-Author, "Final Regs. on Deducting Expenses and Claims under Section 2053 - Part II," Estate Planning, June 2010

· Co-Author, "Final Regs. on Deducting Expenses and Claims under Section 2053 - Part I," Estate Plan ning, May 2010

· Co-Author, "The Impossible has Happened: No Federal Estate Tax, No GST Tax, and Carryover Basis for 2010," Journal of Taxation, February 2010

· Co-Author, "Tax Effects of Decanting - Obtaining and Preserving the Benefits," Journal of Taxation, November 2009

· Author, "Estate Planning in a Low Interest Rate Environment," 36 Estate Planning 7, July 2009

· Co-Author, "Final Regulations on Estate Tax Inclusion for GRATs and Similar Arrangements Leave Open Issues," 109 Journal of Taxation 4, October 2008

· Co-Author, "Directed Trusts: The Statutory Approaches to Authority and Liability," 35 Estate Planning 7, September 2008

· Author, "Planning in a Low Interest Rate Environment: How Do Interest Rates Affect the Calculations in Commonly Used Estate Planning Strategies?," Tax Management, July 2008

· Co-Author, "Adventures in Allocating GST Exemption in Different Scenarios," 35 Estate Planning 4, April 2008

· Principal Author, Amicus Brief filed in the United States Supreme Court by the Tax Section of the Florida Bar in the Knight v. Commissioner dealing with the interpretation of Section 67(e), November 2007

· Principal Author, Comments submitted by ACTEC on the Proposed Regulations dealing with Section 67(e), November 2007

· Principal Author, Comments submitted by ACTEC on the Proposed Regulations dealing with the application of Sections 2036 and 2039 to retained interest trusts, November 2007

· Co-Author, "Prop. Regs. on Deduction for Administration Expenses and Claims," 34 Estate Planning 10, October 2007

· Co-Author, "Supercharged Credit Shelter Trust," 21 Probate and Property 4, July, August 2007

· Author, "A Complete Tax Guide for Irrevocable Life Insurance Trusts," 34 Estate Planning 7, July 2007

· Author, "How to Create and Administer a Successful Irrevocable Life Insurance Trust," 34 Estate Planning 6, June 2007

· Author, "Gift-Splitting - A Boondoggle or a Bad Idea? A Comprehensive Look at the Rules," 106 Journal of Taxation 6, June 2007

· Co-Author, "The World's Greatest Gift Tax Mystery Solved," 155 Tax Notes 3, April 2007

· Author, "Deemed Allocations of GST Exemption to Lifetime Transfers," 34 Estate Planning 3, March 2007

· Author, "Handling Affirmative and Deemed Allocations of GST Exemption," 34 Estate Planning 2, February 2007

· Co-Author, "Estate Planning for Noncitizens and Nonresident Aliens: What Were Those Rules Again?," 106 Journal of Taxation 1, January 2007

· Co-Author, "GRATs vs. Installment Sales to IDGTs: Which Is the Panacea or Are They Both Pandemics?," 41st Annual Heckerling Institute on Estate Planning, 2007

· Co-Author, "BNA Tax Management Portfolio 836-Partial Interests-GRATs, GRUTs, QPRTs (Section 2702)," BNA Tax Management, 2007

· Co-Author, "Drafting and Administration to Maximize GRAT Performance," 20 Probate and Property 6, November, December 2006

· Co-Author, "What Estate Planners Need to Know about the New Pension Protection Act," 105 Journal of Taxation 4, October 2006

· Co-Author, "Evaluating the Potential Success of a GRAT Against Competing Strategies to Transfer Wealth," 31 BNA Tax Management's Estates, Gifts, and Trusts Journal, 3, March 2006

· Co-Author, "Valuation Principles and Recent Developments, Practical Guidance for the Estate Planner," ABA's Real Property, Probate and Trust Journal, Summer 1999; ACTEC Journal, Summer 1999; also presented at the 33rd Annual Philip E. Heckerling Institute on Estate Planning

· Author, "IRS Provides New Opportunities for Using Private Split-Dollar in a Family Context," 86 Journal of Taxation 5, May 1997

· Author, "The Transfer for Value Rule: Developments and Clarifications," Trusts and Estates, April 1995

Lectures/Panels/Webinars

· Speaker, "Planning with Portability: What Do the Numbers Show?" 39th Annual Notre Dame Tax & Estate Planning Institute, October 2013

· Speaker, "Portability - The Silent Partner of Estate Planning," The Third Annual Federal Tax Institute of New England, September 2013

· Speaker, "Tricks and Traps of Planning and Reporting Generation-Skipping Transfers," Greenville Estate Planning Council, September 2013

· Speaker, "A Discussion of the State Statutes on Decanting," ACTEC Florida Fellows Decanting Workshop, May 2013

· Speaker, "DING Trust PLR 201310002," Estate Planning Seminar Group, May 9, 2013

· Speaker, "Gift Splitting," Douglas W. Conner 34th Annual Advanced Estate Planning and Administration Seminar, April 26, 2013

· Speaker "A Walk Through the Authorities on Formula Clauses" and "Hot Topics in Estate and Gift Tax Planning," USC Gould School of Law 2013 Tax Institute, January 28, 2013

· Speaker, "Tricks and Traps in Planning and Reporting Generation-Skipping Transfers" and "Using Life Insurance to Fund Estate Taxes: A Counterintuitive Approach & A Wrap-Up of the Key Presentations of the Week," 47th Annual Heckerling Institute on Estate Planning, Orlando, FL, January 14-18, 2013

· Speaker, "Cutting Edge Estate Planning Techniques - What Have I Learned From My Colleagues?" Tenth Annual Sophisticated Trusts and Estates Law Institute, November 2012

· Speaker, "GRAT Versus Installment Sales Comparison," The NAEPC Education Foundation and National Association of Estate Planners & Councils, Orlando, FL, November 2012

· Speaker, "Try It, You'll Like It: Seven Key Estate Planning Techniques," 47th Annual Southern Federal Tax Institute, October 2012

· Speaker, "Dealing With the Continued Uncertainty of the Tax Law," ACTEC Fall Meeting, October 2012

· Speaker, "Cutting Edge Estate Planning Techniques: The 99-Year GRAT, Leveraged GRATs, Using Testamentary CLATs to Avoid the Sale of Assets to Pay Estate Taxes and Supercharging Installment Sales to Grantor Trusts," 38th Annual Notre Dame Tax & Estate Planning Institute, September 2012

· Speaker, "Developing Law on Changing Irrevocable Trusts: Staying Out of the Danger Zone," Federal Tax Institute of New England, September 2012

· Co-Speaker, "The Mathematics of Planning with the $5 million Shelters and Structuring GRATs in Light of Possible 10 Year Terms," Boston Estate Planning Council, December 2011

· Panelist, "New Carryover Basis Guidance: Due Dates Imminent for 2010," ACTEC/ALI-ABA Webinar, September, October, November 2011

· Co-Speaker, "The Mathematics of Planning Gifts under Current Laws using Shelters, Impact of Portability and Structuring GRATs in light of possible 10-year Terms and more," ACTEC Southeast Region Meeting and 37th Annual Notre Dame Tax and Estate Planning Institute, October 2011

· Co-Speaker, "Effective Use of the $5 Million Shelters -- What do the Numbers Show?," NYSBA 9th Annual Sophisticated Trusts and Estates Law Institute, October 2011

· Speaker, "The Brave New World of Planning with 'Irrevocable' Trusts" and Panelist "Hot Topics: Exploring Key Developments," 46th Annual Southern Federal Tax Institute, September 2011

· Speaker, Presentation on Decanting, Florida Bankers Association 2011 Wealth Management Conference, September 2011

· Co-Speaker, "The Estate, Gift and GST Tax Provisions of the 2010 Tax Act," (6 hour live presentation) The Southern California Tax and Estate Planning Forum, May 2011

· Speaker, "The Return of the Estate Tax: Everything You Must Know for 2011 and Beyond" and "Estates and Trusts Committee: The 'Supercharged Credit Shelter Trust,'" 24th Annual Tax Conference presented by the Taxation Section of the State Bar of Michigan, May 2011

· Speaker, "Testing the Economic Benefits of Planning Under the 2010 Tax Act: What do the Numbers Show?," Florida Bar, Tax Section - Transfer Tax Idols Revisited, April 2011

· Panelist, "Irrevocable Life Insurance Trusts," Strafford Publishing Webinar, February 2011

· Panelist, "Transitions 2011, Best Practices for Transitioning Your Business and Estate," YPO Bonus Seminar with MorganStanleySmithBarney, January 2011

· Panelist, "Where There Is Congressional Chaos, There Is Taxpayer Opportunity: Historic Prospects for Year-End Transfer Tax and Income Tax Planning," Southern Federal Tax Institute Webinar, December 2010

· Panelist, "Using Formula Clauses for Sales and Gifts," ABA/RPTE Webinar, November 2010

· Speaker, "Update: Formula Clauses," NYSBA 8th Annual Sophisticated Trust and Estate Program, November 2010

· Speaker, "Effective Use of Formula Clauses to Handle Drafting in 2010 and Beyond," 36th Annual Notre Dame Tax and Estate Planning Institute, October 2010

· Speaker, "Planning with Defined Value Clauses," ALI-ABA, Sophisticated Estate Planning Techniques, September, 2010

· Panelist, "Practicing in Interesting Times," ACTEC Summer Meeting, June 2010

· Panelist, "Practical Advice on Planning and Administering Estates," ABA RPTE Webinar, May 2010

· Speaker, "Gift Splitting: A Comprehensive Look at the Rules," Cincinnati Advanced Estate Planning Institute, February 2010

· Panelist, "Estate Tax Repeal," ACTEC/ALI-ABA Webinar, January 2010

· Panelist, "Trusts in Florida: The Outer Limits," Florida Bar RPTTL Section, December 2009

· Panelist, "The Changing World of Estate Plannings," Florida Bar RPTTL Section, November 2009

· Speaker, "Planning in a Low Interest Rate Environment," NYSBA 7th Annual Sophisticated Trust and Estate Program, November 2009

· Speaker, "Generation Skipping Transfer Tax Traps and Solutions Revisited," 35th Annual Notre Dame Tax and Estate Planning Institute, October 2009

· Co-Speaker, "Decanting - An In-depth View of This Latest Technique," ACTEC Fall Meeting, October 2009

· Speaker and Panelist, "Estate Planning Under a New Administration and Volatile Market Conditions," Illinois Institute of Estate Planning, April 2009

· Speaker, "Planning in a Low Interest Rate Environment," St. Louis Estate Planning Council, April 2009

· Panelist, "Post-Election Estate Planning or Best Planning 'Now' in Light of the Election Outcome," The Catholic Foundation and the Dallas Bar Association, December 2008

· Speaker, "Directed Trusts - An Overview of the Statutory Approaches to Authority and Liability," Sixth Annual Sophisticated Estate Planning Conference, NYSBA, November 2008

· Speaker, "Gift Splitting - A Boondoggle or a Bad Idea? A Comprehensive Look at the Rules," 28th Southern California Tax and Estate Planning Forum and 34th Annual Notre Dame Tax and Estate Planning Institute, Fall 2008

· Panelist, "Effectively Using Defective Trusts: Putting Grantors to Work," Southern Federal Tax Institute, September 2008

· Speaker, "Drafting Irrevocable Life Insurance Trusts," ALI-ABA: Skills Training for Estate Planners, July 2008, 2007, 2006

· Panelist, "Estate Planning in a Low Interest Rate, Down Market: Making Lemonade Out of Lemons," ACTEC Summer Meeting, June 2008

· Panelist, "Defective Grantor Trusts," Texas State Bar, April 2008

· Speaker, "Planning Grantor Trusts and Life Insurance Maximizing Benefits and Minimizing Risks," 21st Annual Todorovich Memorial Lecture, March 2008

· Speaker, "Estate Planning for Nonresident Aliens: What Were Those Rules?," Philadelphia Estate Planning Counsel, March 2008

· Asked by the ABA to testify at the Public Hearings before the Treasury Department on Proposed Regulation 1.67-4, November 2007

· Speaker, "Is My Freeze Preferable to Your Freeze?," ACTEC Southeast Regional Meeting, November 2007

· Speaker, "Super Charged Trusts," Florida Bar, November 2007

· Panelist, "Planning with Grantor Trusts - Structuring a Grantor Trust to Maximize the Benefits and Minimize the Risks," ACTEC Fall Meeting, November 2007

· Speaker, "The Generation-Skipping Transfer Tax - Current Problems and Developments," 27th Southern California Tax and Estate Planning Forum and 33rd Annual Notre Dame Tax and Estate Planning Institute, October 2007

· Panelist, "Comparative Shopping: GRATs, Installment Sales, and Outright Lifetime Gifts," 22nd Annual Advanced ALI-ABA Course of Study, Sophisticated Estate Planning Techniques, September 2007

· Panelist, "Financial Analysis Meets Tax Planning: In-Depth GRAT Analysis and Comparison," ACTEC Annual Meeting, Spring 2007

· Panelist, "GRATs vs. Installment Sales to IDGTs: Which is the Panacea or Are They Both Pandemics?," 41st Annual Heckerling Institute on Estate Planning, 2007

· Panelist, "Advanced Estate Planning Update," ALI-ABA, Winter 2005, 2007

· Panelist, "GRATs and Competing Strategies for Effective Wealth Transfer: Evaluating Legal Issues and Investment Risks," BNA Tax and Accounting Audio Conference and Advisory Board Meeting, March 2006

· Panelist, "Evaluating the Potential Success of a GRAT Against Competing Strategies to Transfer Wealth," 26th Annual Southern California Tax and Estate Planning Forum and 32nd Annual Notre Dame Tax and Estate Planning Institute, October 2006

· Speaker, "Estate Planning for Non-Residents and Non-Citizens," IBC's International Trust and Tax Planning Summit, February 2006

· Panelist, "Principal Issues Pertaining to the Transfer of Property by Gift or Testament," IBC's International Trust and Tax Planning Summit, October 2005

· Speaker, "Drafting Irrevocable Life Insurance Trusts (with GST Aspects)," ALI-ABA, Skills Training for Estate Planners, July 2005; "Generation-Skipping Drafting and Compliance," July 2004, 2003, 2002

· Panelist, "Your Money and Your Life Insurance: The Economics and the Law of Sophisticated Insurance Strategies," ACTEC Fall Meeting, September 2004

· Panelist, "GST Fix-Ups-More Flexibility with More Complexity," ACTEC Annual Meeting, Spring 2003

· Panelist, "Planning and Drafting Under the 2001 Tax Act," ACTEC Florida Fellows Meeting, August 2001

· Panelist, "Hot Topics," ACTEC Summer Meeting, June 2000

· Panelist, "Proposed Generation-Skipping Tax Legislation," ABA Annual Meeting, August 2000

· Speaker, "Private Split Dollar," ACTEC Florida Fellows Meeting, August 1999

· Panelist, "Generation-Skipping Transfer Tax: The Basics and Beyond," ABA Annual Meeting, August 1998

· Speaker, "Gifts in Estate Planning," NYSBA, 1994

 
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Office Information

Diana S.C. Zeydel

333 SE 2nd Avenue, Suite 4400
MiamiFL 33131




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