Jeffrey J. Spina-Jennings
ATTORNEY
- ESTATE PLANNING & TAX GROUP
Jeffrey J. Spina-Jennings is a Vero Beach estate planning attorney and member of Gould Cooksey Fennell’s Estate Planning & Tax Group. He represents clients and nonprofits in complex estate and trust planning and administration, trust modifications, federal transfer tax reporting, charitable planning, nonprofit planning and the formation of both private and public charitable entities.
Jeffrey regularly advises clients on the formation of private grantmaking foundations and private operating foundations designed to further their philanthropic goals. He also represents public charities in the formation of supporting organizations established to hold charitable endowments.
His practice involves designing and implementing sophisticated charitable planning structures tailored to each client’s philanthropic objectives. Jeffrey also reviews existing governance structures of nonprofit organizations and advises on the implementation of best practices in accordance with modern developments in federal tax law and Florida law.
- University of Florida, LL.M. Taxation (2018)
- University of Florida, J.D. (2017)
- University of Central Florida, B.S. (2013)
- Best Lawyers “One’s To Watch” in Tax Law and Trusts & Estates
- Super Lawyers “Rising Stars” Estate Planning
- The Florida Bar
- Florida Bar, Real Property, Probate and Trust Law Section
- Florida Bar, Tax Section
- Planned Giving Tips and Practice Pointers Based Upon Recent Developments, Florida Bar Real Property, Probate and Trust Law Section CLE (2023)
- Florida Bar – What Attorneys Need to Know About Qualified Appraisals, Florida Bar Real Property, Probate and Trust Law Section CLE (2024)
- What Estate Planners Need To Know About 501(c)(4)s, Actionline, Winter 2024
Notable Representations
- Has worked with individuals and families to create private foundations and charitable entities that reflect their long-term philanthropic goals and family values.
- Has assisted nonprofit organizations with organizational documents, internal policies, and IRS filings required to obtain tax-exempt status.
- Has represented public charities in establishing supporting organizations to hold and manage endowment assets.
- Has advised charitable organizations on governance and compliance matters involving federal tax law and Florida nonprofit law.
- Has helped clients structure charitable gifts involving real estate, collectibles, and other assets in support of their charitable giving objectives.
- Assisted multiple clients in preparing organizational documents to establish and administer private foundations, including governing instruments, policies and procedures, and filing IRS Form 1023 (to confirm tax exempt status of such organization).
- Represented clients in connection with the formation of private operating foundations to carry out their active philanthropic goals, such as a museum, and filing IRS Form 1023 (to confirm private operating foundation status of such organization).
- Represented clients in succession planning for private foundations.
- Represented clients in connection with dissolution of private foundations into donor advised funds or successor private foundations.
- Represented public charity clients in connection with the formation of a supporting organization to hold endowment assets.
- Represented clients in connection with the administration of their public and private charitable entities.
- Represented clients in connection with structuring charitable donations of real property and tangible personal property, such as collectibles, and securing income tax deduction for such charitable donation
- Assisted multiple clients in connection with modification and reformation of trusts, including modification (judicially and nonjudicially), nonjudicial settlement agreements, and decanting assets to new trusts.
- Represented multiple clients in connection with reporting lifetime taxable gifts (IRS Form 709), including lifetime taxable gifts that were previously unreported.
- Represented clients in connection with the filing of a “late” allocation of client’s generation skipping transfer tax exemption to trusts to covert inclusion ratio to zero.
- Represented clients with structuring charitable donations and income tax deductions for donations of real property and tangible property, such as collectibles.
- Represented private foundations with determining potential excise tax implications, including analysis of expenditure responsibility requirements and whether contemplated transaction would result in unrelated business taxable income.
- Assisted clients with structuring estate plan to exercise power of appointment over inherited assets.
- Represented multiple estate planning clients in connection with preparation of (i) irrevocable life insurance trusts; and (ii) Generation Skipping Transfer Tax exempt and non-exempt irrevocable trusts for the benefit of such client’s descendants.
Work with multiple clients to structure special purpose entities (consolidating assets and management features) to leverage available valuation discounts, preserve elements of management and control, and achieve family objectives of preservation of wealth.