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Bill Doyle has more than four decades of experience representing high-net-worth individuals and families, as well as banks, trust companies, and family offices, in complex and legal matters. He focuses his practice on the formation and operation of entities to own and manage capital on an income tax efficient basis. The legal structures he designs for clients are designed with the goal of facilitating the movement of wealth within a family without the imposition of a gift, estate, or generation-skipping tax. Bill regularly employs strategies involving a combination of trusts and business entities such as limited liability companies, partnerships, and corporations.

Concentrations

  • Reorganization of multifaceted, closely held businesses and controlling interests in public companies with the goal of improving the tax efficiency of those organizations.
  • Management succession planning for closely held businesses through voting trusts, voting agreements, buy-sell agreements, and on occasion, divestures and spin-offs.
  • Tax, corporate, and regulatory work in connection with the purchase and sale of closely held business enterprises and interests therein.
  • Tax planning in anticipation of and/or contemporaneous with IPOs, including leveraged sales of interests in closely held businesses to “dynasty trusts,” charitable remainder trust planning, and post-IPO formation and funding of family foundations.
  • Use of various forms of charitable remainder trusts, prepaid variable forward contracts, exchange funds, and “mixing bowl” partnerships to avoid the capital gain tax attendant to diversifying out of single stock exposure for clients who sell their businesses in exchange for a block of stock in a public company.
  • Advising clients in connection with investment diversification, asset protection, and corporate and family governance issues.
  • Counseling clients in connection with the formation, funding, and operation of a wide variety of charitable and quasi-charitable organizations, including public charities, supporting organizations, private foundations, operating foundations, and all types of charitable lead trusts and charitable remainder trusts.
  • Counseling families and the businesses they own/control regarding the development of mechanisms for governance and communication, including the use of family constitutions, mission statements, family councils, and shareholder committees.
  • Preparation of wills, trusts, and ancillary estate-planning documents.

Capabilities

Experience

  • Sale of a business by a Forbes 400 List family for a combination of cash and stock in the publicly held company that was acquiring the business. This transaction was accomplished through a reverse-triangular merger and afforded tax-free treatment for the stock in the public company that was received by the family.°
  • Restructured and domesticated the offshore trust holdings for one of the wealthiest families in Europe to more efficiently approach the tax goals for family members residing in the United States.°
  • Formation of a limited liability company to own a division of an S corporation followed by the immediate transfer of a 99 percent non-voting interest in the business to a private-operating foundation to implement the client’s philanthropic goals while avoiding the federal and state capital gain tax associated with the sale of the business. The transaction also generated a large income tax charitable deduction that is being used to shelter other income. Most importantly, the family is supporting the charitable causes that are of interest to them through the substantial wealth now held in their private operating foundation.°
  • Formation of a holding company to hold a CEO’s stock in a NYSE company, which, through various elements of intrafamily and external leverage, has shifted ownership and control of more than two-thirds of the voting stock and 25 percent of the equity interest in that public company to a trust that will avoid the need for forced liquidations of stock to fund estate tax liabilities at the CEO’s death.°
  • Liquidation of a Forbes 400 List family’s controlling interest in a public company through a series of secondary offerings, and redeployment of the proceeds thereof through a series of family-controlled investment partnerships that focus on real estate, private equity, long-short public equity, technical arbitrage, and venture capital holdings.°
  • The deferral of tax associated with the disposition of a family’s real estate portfolio through a series of 1031 exchanges with bottom guarantees to substantially reduce the investment risk previously associated with the portfolio.°
  • Helped a family avoid intrafamily litigation through the reorganization of its operating businesses to create a mechanism for harvesting some of the earnings from those businesses on a tax-efficient basis and then reinvesting those earnings through a series of diversified investment partnerships controlled by the family.°
  • Counseled a number of Forbes 400 List families in connection with the formation of private trust companies in states that do not impose a state income tax and the changing of the situs of their family trusts to those states.°

°The above representations were handled by Mr. Doyle prior to his joining Greenberg Traurig, LLP.

Recognition & Leadership

  • Listed, Chambers and Partners, "The Chambers Global High Net Worth (HNW) Guide," Private Wealth Law, 2021-2022
  • Member, Board of Trustees, Abraham Lincoln Presidential Foundation, 2005-Present
  • Member, Lincoln Leadership Prize Committee

Credentials

Education
  • J.D., magna cum laude, DePaul University College of Law, 1976
  • M.B.A., Loyola University Chicago, 1974
  • B.S., Business Administration, John Carroll University, 1972
Admissions
  • Illinois