Stephen Putnoki-Higgins

Protecting hard-earned family wealth through careful estate and tax planning is Stephen Putnoki-Higgins’ dedicated focus.

Bringing New York energy and a Master of Laws in Taxation to his clients, Stephen focuses his legal practice on the tax, estate planning, business planning, and estate administration needs of sophisticated individuals and their families.

With a combination of compassion and cutting-edge strategy, Stephen guides his clients in achieving their key tax and non-tax goals, such as probate avoidance and the preservation of familial harmony. Stephen is dedicated to helping clients navigate difficult life transitions as smoothly and expeditiously as possible, and that they know all their legal options—and the implications of each—as he works to achieve their goals. Stephen’s strategic and thoughtful legal assistance is reflected by the many unsolicited 5-star client reviews he’s received on Avvo and Martindale Hubbell.

Stephen also strategically assists in transfer tax planning for high-net worth individuals, including closely held business owners and other professionals, and he utilizes a variety of sophisticated techniques, such as trust modification and decanting, dynasty trusts, sales to grantor trusts, grantor retained annuity trusts, and more, to accomplish his clients’ goals.

Stephen is highly experienced in estate administration, assisting fiduciaries and beneficiaries alike through all aspects of the process, including probate, contested estates, tax, and post-mortem estate planning issues.

He regularly advises individuals and their consultants regarding the formation of tax-exempt organizations and other non-profit entities, in addition to assisting with the compliance, structural, operational, and governance-related issues clients face in administering these entities.

Awards & Accolades

Avvo Clients’ Choice Award, 2021 (for obtaining at least five perfect five-star reviews in 2021)

Avvo Clients’ Choice Award, 2020 (for obtaining at least five perfect five-star reviews in 2020)

Super Lawyers, Florida, "Rising Star," Estate Planning and Probate (2022)

Case Studies

Representative Matters

• Prepared tax-efficient estate planning documents for high-net-worth couple where one spouse moved to Florida and obtained residency there for tax purposes while other spouse remained resident in New York State for state tax purposes.
• Assisted high-net-worth client with contested gift-sale of multiple entity interests to grantor trust in exchange for promissory note.
• Assisted high-net-worth client with buyouts and consolidated sale to venture capital group of roughly a dozen fitness centers.
• Obtained zero tax due ruling from Scandinavian tax authorities based on recommended treaty position with respect to the estate of a dual citizen who died while residing in Finland.

News & Insights

Selected Publications

• "Morrissette II Case a Jagged Little Pill," WealthManagement.com, May 26, 2021

• "IRS Rules Merged Trust Qualified as 'See-Through'," WealthManagement.com, September 9, 2020
• “Trustee-to-Trustee Transfer Didn’t Disqualify IRA: PLR Clarifies Rules Concerning IRAs When Nonindividual Beneficiaries Are Involved,”  WealthManagement.com, November 4, 2019
• “CRUT Doesn’t Qualify as Tax-Exempt Under IRC Section 501(c)(3): Organizational and Operational Tests Deemed Unmet,”  WealthManagement.com, September 12, 2019
• “Proceeds of ILIT Policy Not Included in Trustee-Beneficiary’s Estate: No Incidents of Ownership Retained Post-Modification,”  WealthManagement.com, May 22, 2019
• “Estate’s Heirs Liable for Unpaid Federal Estate Taxes,”  WealthManagement.com, April 9, 2019
• “Marital Trust Division a Non-Recognition Event, says IRS, but Transfer Tax Implications Abound,” WealthManagement.com, September 12, 2018
• “No Attorney’s Fees After Estate Successfully Avoids Penalties,” WealthManagement.com, May 8, 2017
• “Trust Didn’t Qualify as a CRT, says IRS,” WealthManagement.com, April 17, 2017
• “Deductibility of Claims Against an Estate: A Recent Ninth Circuit Decision Determines that Post-Death Events are Relevant,” WealthManagement.com, April 1, 2014
• Co-Author, "Gift Planning With Formula Clauses,' Procter’s Progeny to Wandry World (Part 2), 28 Probate & Prop. 2, at pp. 37-42, (March/April 2014).
• Co-Author, "Gift Planning With Formula Clauses,"From Procter’s Progeny to Wandry World (Part 1), 28 Probate & Prop. 1, at pp. 53-57, (Jan./Feb. 2014).
• “Practical Gift Funding Issues When Planning with Hard-to-Value Assets,” Connecticut Bar Association Estates & Probate Newsletter, May 2013
• Research Credit, "The Unfulfilled Promise of the Indian Commerce Clause & State Taxation",  Richard D. Pomp: The Tax Lawyer, State & Local Tax Ed., Vol. 34, No. 4, p. 902, n.*, Summer 2010 

Selected Events

• "2018 National Tax Moot Court Competition," Judge, Florida Bar Tax Section, St. Petersburg, FL, February 2, 2018
• "2016 Ullman Year in Review: Estate & Gift Tax Update," Florida Bar Tax Section Annual Meeting, Amelia Island, FL, July 4 2018

Community and Professional Activities

The Connecticut Bar Association, Estates and Probate Section, Tax Section

The Florida Bar Association, Real Property, Trust & Estate Law Section, Tax Section

The American Bar Association, Real Property, Trust & Estate Law Section, Taxation Section

Notary Public, State of Florida (Commission Expires May 26, 2024)