Bill Culp helps clients structure their business and personal affairs to minimize taxes and maximize their wealth. He represents a variety of clients, from entrepreneurs and private investors to large corporate clients. Clients look to him for guidance in structuring complex business arrangements and transactions, and for solutions to the most challenging business problems.
Bill has extensive experience in federal and state income, estate and gift taxation. His practice includes family business planning, wealth preservation planning, tax controversies, and trust and probate controversies. He is also involved in business and real estate matters including acquisitions, dispositions, and complex entity ownership planning.
Bill advises clients on multi-generational trust arrangements. He serves as trustee for a number of large trusts and as trustee is intimately involved in all aspects of trust administration. Over the years, Bill has assisted numerous clients in the preparation for sale and sale of their family businesses.
- American College of Trust and Estate Counsel, Fellow
- Co-author Bloomberg BNA Trust Decanting Portfolio, 871 T.M. 2013
- Selected as “Top 100 Attorney” in the country by Worth magazine (2007-2009)
- Inclusion in The Best Lawyers in America® in the specialty of Litigation – Trusts and Estates, Litigation and Controversy – Tax, Tax Law, and Trusts & Estates (2021)
- Inclusion in The Best Lawyers in America® in the specialty of Tax and Trusts & Estates (2010-2020)
- Named Best Lawyers 2019 Litigation and Controversy – Tax “Lawyer of the Year” in Charlotte
- Named Best Lawyers 2018 Trust and Estates “Lawyer of the Year” in Charlotte
- Named Best Lawyers 2017 Litigation and Controversy – Tax “Lawyer of the Year” in Charlotte
- Named Best Lawyers 2016 Litigation – Trust and Estates “Lawyer of the Year” in Charlotte
- Named Best Lawyers 2015 Litigation and Controversy – Tax “Lawyer of the Year” in Charlotte
- Named Best Lawyers 2014 Litigation – Trust and Estates “Lawyer of the Year” in Charlotte
- Named Best Lawyers 2013 Trusts and Estates “Lawyer of the Year” in Charlotte
- Inclusion in North Carolina Super Lawyers (2006-2021)
- Recognized in “Legal Elite” 2006 in a list of top lawyers in the state compiled by Business North Carolina magazine
- Assisted clients in transfers of multi-million dollar businesses from older generation family members to younger generation family members.
- Assisted clients in the creation and funding of numerous multi-generational irrevocable trusts.
- Litigated income tax and estate tax cases in US Tax Court.
- Successfully represented clients in the examination on appeals divisions of the IRS in “no change” audits of multi-million dollar conservation easements.
- Represented numerous clients in the sale of family businesses to third party purchasers.
- Advised clients in complex estate and probate litigation.
- As a member of the NC Legislative Committee of the Estate Planning and Fiduciary Law Section of the North Carolina Bar Association, Bill has extensive experience in the drafting and enactment of trust legislation in North Carolina.
- Designed and implemented numerous business organization structures to own family business assets through a series of trusts, limited liability companies and corporations.
- Assisted clients in the design, structure and implementation of foreign trusts to own business and investment assets.
- Represented foreign individuals in the formation of trust and investment entities in the U.S.
- Designed innovative and effective “Partnership Exit Strategies” to receive assets tax-free from partnerships.
- Designed and implemented innovative and effective transactions for real estate developers to trigger losses to be carried back to prior year to obtain refunds of taxes paid in prior years.
- Assisted clients in “decanting” assets from existing trusts to new trusts for various purposes including modernization of trust processes, extention of trust terms and preservation of assets.
- “The CPA’s Role in Tax Litigation: Why An Understanding of Tax Litigation Strategy and Practice is an Integral Part of All Tax Controversy,” NCACPA 78th Annual Symposium, Greensboro, NC, November 2017
- “Estate Planning and Business Valuation,” NCACPA 77th Annual Symposium, Greensboro, NC, November 2016
- “Charitable Giving/Estate Planning/Asset Protection Planning,” Community Foundation of Gaston County, Inc., May 2015
- “Tax Impact of the New North Carolina Decanting Statute,” 2010 North Carolina/South Carolina Tax Section Workshops, May 2010
- “Trust Decanting: An Overview and Introduction to Creative Planning Opportunities,” 30th Annual Estate Planning & Fiduciary Law Program, July 2009
- “How to Create Tax Exempt Wealth With Life Insurance – the Use of Life Insurance in Sophisticated Estate and Income Tax Planning,” Charlotte, NC, December 2000
- Trust Decanting, Bloomburg BNA Tax Management Portfolio, 871 T.M., 2013.
- Valuation Practice in Estate Planning and Litigation, Clark Boardman Callaghan, 1994.
- Don’t Be Caught Dead Paying a Voluntary Tax!, Self-Published, 1997, 2016.
- The Tax and Practical Aspects of the Installment Sale to a Spousal Grantor Trust, ACTEC Law Journal, Volume 44, Number 1, Winter 2019
- “Decanting From Trusts with Perpetuities Savings Provisions,” Estate Planning, October 2014.
- “Constitutionality of Rule Against Perpetuities Repeal Revisited,” The Will & The Way, September 2013.
- “Trust Decanting,” BNA Tax Management Portfolio, 871 T.M., 2013.
- “US Supreme Court Case Supports Constitutionality of Perpetuities Repeal,” The Way & The Will, May 2011.
- “Use of Trust Decanting to Extend the Term of Irrevocable Trusts,” Estate Planning, June 2010.
- “Trust Decanting: An Overview and Introduction of Creative Planning Opportunities,” Real Property Trust and Estate Law Journal of the ABA, Volume 45, Issue 1, Spring 2010.
- “The Case for Caution: Fraudulent Conveyance Risks in Estate Planning,” Probate & Property, January/February 2010.
- “Banking on Appreciation: The Application of Securities Laws to “Landbanking” Transactions,” Probate & Property, May/June 2009.
- “North Carolina Taxation of Irrevocable Trusts,” The Will & The Way, December 2006.
- “Can Completed Contract Accounting Method Be Used by Lot Developers Who Do Not Build Homes?” Journal of Taxation, December 2006.
- “Lifetime Special Powers of Appointment Offer Unique Planning Opportunities.” Estate Planning, October 2006.
- “FLPs are Still Viable to Save Transfer Taxes,” Business North Carolina, June 2006.
- “The Gift Tax in North Carolina: A Review of Recent Events,” The Will & The Way, April 2006.
- “Outbound L.L.C. Planning Includes Options for China Investment,” Journal of International Taxation, July 1995.
- “Ruling on Qualified Sub S Trust Raises Potential Phantom Gain and Installment Problems,” Journal of Taxation, May 1993.
- “Owning Assets in Trust Results in Tax and Nontax Benefits,” Estate Planning, September/October 1992.
- “Avoiding Cancellation of Debt Income Where the Liability is Disputed,” Journal of Taxation, May 1991.
- “IRS Pronouncements Clarify Status as a Partnership vs. an Association,” Journal of Taxation, Summer 1989.
- “Federal Tax Litigation Involving Leveraged Buyouts,” Prentice Hall Tax Ideas, 1987.
- “District Court in Fox Limits a Sole Proprietor’s Fifth Amendment Privilege,” Journal of Taxation, August, 1983.
- “When Will Contraction of Operation Accelerate Employees’ Rights to Qualified Plan Benefits,” Taxation for Accountants, June 1983.
- “Business Succession Planning,” 2016 North Carolina Best Lawyers supplemental issue, January 2016.
- “Liquidating Trustee Must File Returns and Pay Tax for Debtors, Supreme Court Says,” Journal of Taxation, June 1992.
- “Maximizing the Low-Income Housing Credit in Combination with Government Subsidies,” Journal of Taxation, September 1988.
- “Not All Reductions in Covered Employees Will Result in Partial Termination of a Plan,” Journal of Taxation, November 1985.
- Board Certified Specialist in Estate Planning and Probate Law, North Carolina
- American College of Trust and Estate Counsel, Fellow
- Member of the Legislative Committee of the Estate Planning and Fiduciary Law Section of the North Carolina Bar Association
- NC Association of Certified Public Accountants