Prompt - You are an associate in a boutique tax consulting firm that specializes in the real estate industry. You have been assigned to work with a client who needs advice on the tax implications of his business holdings, which include Skyscrapers, a commercial real estate firm organized as a sole proprietorship with a fair market value of $1 billion. He is considering transferring partial ownership of the Skyscrapers to both of his children and selling a 10% interest to an unrelated third party.

1. Utilize intentionally defectivegrantor truststo accomplish long-term minimization of the client's taxliability. Consider the mechanics of these estate planning vehicles and the appropriate authority to cite.
2. Tablesand Calculations: Excel Documentation

A. Consider how the strategymaximizes the amount of transferredwealth to the client's children over timeand explain the amount in an Excel spreadsheet.

B. Given the incometax consequences, conclude whether or not the strategy is worthwhile and is ethically sound. Consider justifying the strategy in comparison to an alternative transaction.