William Doyle is a tax partner in Winston & Strawn’s Chicago office and chair of the firm’s trusts and estates practice group. He represents families of substantial means and the businesses they own and/or control. Mr. Doyle’s broad-based tax and estate-planning practice focuses on the formation and operation of entities to own and manage capital on an income tax efficient basis. The legal structures Mr. Doyle designs for clients typically facilitate the movement of wealth within a family without the imposition of a gift, estate, or generation-skipping tax. In many instances, this is accomplished through the use of a combination of trusts and business entities such as limited liability companies, partnerships, and corporations.
The following is a more specific description of the type of services Mr. Doyle renders to clients:
Reorganization of multifaceted, closely held businesses and controlling interests in public companies to improve 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.
The following is a representative sampling of recent transactions Mr. Doyle has handled for clients:
Sale of a business by a Forbes 400List 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 achieve the tax and investment goals for family members residing in the U.S.
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 therein to a private-operating foundation to implement a 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 client is addressing the charitable causes that are of interest to him through the substantial wealth now held in the 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 400List 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.
Mr. Doyle received his B.S. in Business Administration from John Carroll University in 1972, an M.B.A. from Loyola University Chicago in 1974, and a J.D., magna cum laude, from DePaul University College of Law in 1976.
Activities
Mr. Doyle is a member of the American Bar Association’s Income Taxation of Trusts and Estates Committee, the Chicago Bar Association’s Trust Law Committee, and the Chicago Estate Planning Council. He is also vice chairman of the board of trustees of the Abraham Lincoln Presidential Library & Museum Foundation and a member of the foundation’s Executive Committee and Development Committee.
