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ith retroactive effect) such that different rules may apply. This summary is based on the sample Agreement of Trust ("Sample Freeze Agreement") for a Delaware Statutory Trust ("Freeze Entity") that reflects the basic principles of a freeze structure. Unless otherwise defined in this summary, all capitalized terms shall h
ue of the contributed assets is not frozen, but rather the contributor's share in the growth of that value is capped at the fixed rate of return on the Preferred Units. Preferred equity freezes are attractive to senior generations who want to retain a substantial economic interest in the contributed assets, but wa
th retroactive effect) such that different rules may apply. This summary is based on the sample Agreement of Trust ("Sample Freeze Agreement") for a Delaware Statutory Trust ("Freeze Entity") that reflects the basic principles of a freeze structure. Unless otherwise defined in this summary, all other capitalized terms sh
eze Entity will generally cause a taxable exchange unless the distributed property was originally contributed to the Freeze Entity by the holder of the Preferred Units. If the distributed property is an interest in another entity, the exception for distributions of previously contributed property does not apply to
1 EFTA_R1_02076441 EFTA02702734 Preferred Partnership Freeze (PPF) is for investors interested in enhanced wealth transfer opportunities using a Delaware Statutory Trust Purpose: to "freeze" the value of assets that will be included in the senior generation's estate and shift the excess appreciation to the junior ge
% economic interest - Preferred Units provide a fixed, cumulative annual return to senior family members equal to the annual preferred payment on the Preferred Units (can be deferred for 4 years) and a fixed value on liquidation. Preferred Units provide greater security but limit participation in appreciation of
Entities connected to both a Delaware Statutory Trust and the Preferred Units