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H. Carter Hood, Ivins, Phillips & Barker, Chartered Photo

H. Carter Hood

Partner

Carter’s command of income, gift and estate tax laws – and how those laws interact – allows him to provide comprehensive advice to individuals and closely held businesses. Carter enjoys sharing his expertise with future tax practitioners enrolled in Georgetown University Law Center’s LLM program. 

Profile

Carter provides tax advice and other guidance to domestic and foreign individuals and their closely held businesses. In addition to preparing wills and a wide variety of trusts, Carter has established family limited partnerships and limited liability companies and implemented the sale of family businesses to grantor and non-grantor trusts. He has administered estates, established private foundations, advised clients on pre- and post-nuptial agreements, provided post-mortem tax planning advice and represented taxpayers before the Internal Revenue Service in audits and appeals.

Education

Harvard University Law School, 1998, J.D., cum laude

George Washington University, School of Business and Public Management, 1995, Master of Taxation, summa cum laude

Harvard College, 1991, A.B., Economics, magna cum laude

Bar & Court Admissions

District of Columbia

Virginia

Academic Appointments

Adjunct Professor, Graduate Tax Program, Georgetown University Law Center, 2004 - Present (Teaching "Income Taxation of Trusts, Estates and Beneficiaries")

Memberships & Affiliations

American College of Trust and Estate Counsel (ACTEC)

American Bar Association, Tax Section

American Bar Association, Real Property, Trust and Estate Law Section

District of Columbia Bar, Estates, Trusts and Probate Law Section

Virginia Bar Association

Experience

Representative Matters

  • Designed and implemented pre-IPO estate planning that used GST-tax exempt trusts, GRATs and other grantor trusts funded with carried interests in LLCs as well as traditional LLC interests.  Worked extensively with real estate attorneys, securities attorneys, lenders, investment bankers and accountants to design an estate plan that would not interfere with the proposed IPO.
  • Prior to sale of French company owned through U.S. limited partnerships and LLCs, established GRATs to benefit children and a CLUT with the family foundation receiving the lead interest and a GST-exempt trust receiving the remainder.  Worked with French attorneys and IRS to obtain reduced tax withholding rates for GRATs under U.S.-French Income Tax Convention.  
  • Helped U.S. beneficiary reduce income taxes after becoming successor beneficiary of foreign non-grantor trusts with decades of undistributed net income, as well as investments in foreign corporations that constituted PFICs, CFCs and/or FPHCs for U.S. income tax purposes.  

News & Events

Speeches & Presentations

  • ABA Bar Association 2017 May Meeting, Back to Basics: Analyzing the Differences Between Fiduciary Accounting Income ("FAI") and Distributable Net Income ("DNI"), Washington, DC - May 2017
  • ABA Section of Taxation, Grantor Trusts Status Under Section 677, Washington, DC - May 2011
  • ABA Section of Taxation, Selected Topics in Income Tax Planning for Trusts, Washington, DC - May 2009
  • Florida Bankers Association - Trust, Asset Management & Private Banking Division - 2007 Wealth Management Conference, Trust Advisors and The Trustees They Direct: Background, Recent Cases & Practical Considerations, Orlando, FL - August 2007
  • ABA Section of Real Property, Probate & Trust Law - 18th Annual Real Property and Estate Planning Symposia, Special Purpose Advisors and The Trustees They Direct: Background, Recent Cases & Practical Considerations, Washington, DC - April 2007
  • ABA Section of Real Property Probate & Trust Law - Washington, DC Community Outreach Program, Income Taxation of Estates, Trusts, Grantors and Beneficiaries; Life Insurance Planning, Washington, DC - March 2006
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