Suzanne C. Farley

Counsel
Suzanne Farley

Suzanne Farley is a tax attorney who focuses on estate planning for high-net-worth individuals and families. Suzanne's practice has a particular emphasis on family wealth transfers for large estates; trust and estate administrations; court proceedings and Internal Revenue Service (IRS) audits related to trust and estate administrations; charitable giving; business formation and succession planning; and the formation and representation of tax-exempt entities.

Related Practices

Experience

Representative Matters

  • Represented a company founder in pre-transaction planning culminating in a public offering of company 
  • Represented a high-net-worth individual in advanced planning, including grantor retained annuity trusts (GRATs), and use of gifts and sales to intentionally defective grantor trusts (IDGTs) that resulted in significant tax savings
  • Represented a high-net-worth individual in advanced planning, including a charitable lead annuity trust (CLAT), formation of a private family foundation, and Delaware dynasty trusts
  • Represented trustees of a multi-million-dollar estate that owns substantial private real estate assets in the United States and Canada, where the estate was able to obtain estate tax deferral under Internal Revenue Code Section 6166, and a 10-year payment plan for generation-skipping transfer taxes
  • Represented estates in settling estate tax audits before the IRS, where contested issues included the value of closely held business interests, promissory notes, and real estate
  • Represented a trustee of a billion-dollar estate in preparing for an estate tax return, post-mortem tax planning, and administration of estate assets, including substantial real estate holdings
  • Represented closely held business owners in preparing for business succession planning and a buy-sell agreement. 
  • Represented partners in numerous private equity fund complexes, in estate and transactional planning
  • Represented a professional sports franchise in forming and obtaining tax-exempt status for its related nonprofit organization
 

Insights

Credentials
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Education

  • LL.M. Taxation Golden Gate University School of Law 2012
  • J.D. Santa Clara University School of Law 2007
  • B.F.A. magna cum laude City University of New York, Hunter College 2003

Bar Admissions

  • California

Professional Memberships and Activities

  • Member, Bar Association of San Francisco, Taxation Section
  • Member, State Bar of California, Taxation & Estate Planning Sections