News & Analysis as of

Transfer Taxes Estate Tax

Estate Tax Changes Past, Present and Future

by McGuireWoods LLP on

I. INTRODUCTION - This outline is a selective and evolving review of the history of the modern federal estate tax. It originated during the attempts to repeal the estate tax in President Clinton’s second term and...more

More on Transfer Tax Issues Post Windsor and the Legalization of Same-Sex Marriage

by Bryan Cave on

In a recent Notice, the Internal Revenue Service set forth some administrative procedures helping taxpayers recalculate gift and generation-skipping transfer tax exemption with respect to gifts and bequests made to or for the...more

Why Care About Business Valuation? Part II

by Farrell Fritz, P.C. on

Valuations figure prominently in determining the proper tax treatment of transactions – such as sales, loans, leases, and performance of services – between related taxpayers, including, for example, commonly-controlled...more

Why Care About Business Valuation? Part I

by Farrell Fritz, P.C. on

One word: “taxes.” There are so many transactions in which the tax consequences visited upon a closely-held business and its owners, and, therefore the true economic cost of the transaction, will depend upon the valuation of...more

Wealth Management Update - May 2017

by Proskauer Rose LLP on

May Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The May § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs...more

The Future Of Proposed IRS § 2704 Modifications Is Uncertain

Proposed changes to Internal Revenue Code (IRC) § 2704, which would impact the valuation of transfers of family business interests at death, come at an interesting time politically given the Trump Administration’s desire to...more

KNOWN UNKNOWNS about Federal Tax Laws and Regulations

by Dickinson Wright on

The new administration in Washington, supported by Republican majorities in Congress, has pledged substantial changes to federal tax laws and regulations. One change may - or may not - be the complete elimination of federal...more

2017 California Estate and Tax Planning Newsletter

by Blank Rome LLP on

Blank Rome’s annual estate and tax planning newsletter addresses estate planning concepts and techniques that should be considered in 2017 by our clients and friends. Transfer Taxes. The major changes made in 2010 in the...more

Estate Planning – When the Only Certainty is Unpredictability

Donald Trump is now the President, and both chambers of Congress are under Republican control. Thus, we appear to be poised for potentially substantial changes in the estate tax, gift tax, generation-skipping transfer tax,...more

Ron Aucutt’s “Top Ten” Estate Planning and Estate Tax Developments of 2016

by McGuireWoods LLP on

In an always-anticipated annual tradition, Ronald Aucutt, a McGuireWoods partner and co-chair of the firm’s private wealth services group, has identified the following as the top ten estate planning and estate tax...more

Potential Transfer Tax Reform and 2016 Year-End Tax Planning Considerations

by Holland & Knight LLP on

With the upcoming Republican control of the executive and legislative branches, tax changes are certain to occur. As articulated thus far, President-Elect Donald Trump has proposed the elimination of the federal estate tax in...more

Tax Truths: Volume 1, No. 2 – December 2016

by Ballard Spahr LLP on

AN ANALYSIS OF TAX LAW PROPOSALS OF THE PRESIDENT-ELECT AND THE HOUSE - President-elect Trump made tax reform a highlight of his campaign, calling for fewer tax brackets, lower individual rates, and reduced corporate tax...more

Is Tax Reform On the Horizon?

by Butler Snow LLP on

2017 will bring Republican control to D.C. It will also potentially bring tax reform. Both President Elect Donald Trump and House Republicans have proposed sweeping changes to the U.S. tax system, which we have briefly...more

What Proposed Tax Plans by Trump Administration and House Republicans Mean for Personal Planning

by Perkins Coie on

The election of Donald Trump and Republican majorities in U.S. Congress make the future of the federal transfer tax system (gift, estate and generation-skipping transfer (GST) taxes) uncertain. President-elect Trump and...more

Proposed Regs May Limit US Estate Plan

by Hodgson Russ LLP on

On August 2, 2016, the US Treasury issued long-awaited pro- posed regulations under Code section 2704 that make comprehensive and very significant changes to the valuation of interests in many family-controlled entities for...more

Beyer Beware: An Examination of a Family Limited Partnership Gone Wrong

by BakerHostetler on

The opinion issued on Sept. 29, 2016, in the case of Estate of Edward G. Beyer v. Commissioner of Internal Revenue was the culmination of an estate planning exercise that had an unfortunate ending for everyone involved (other...more

Time to Transfer Early Stage Investments?

by Jackson Walker on

New rules may stop “cheap” transfers of business interests to kids and grandkids. Proposed IRS regulations that may be effective as early as the end of 2016 are designed to severely limit use of discounts on gifts or sales...more

Updated Historical Transfer Tax Rates & Exemptions

by Charles (Chuck) Rubin on

Please see chart below for more information....more

IRS Proposes Regulations That Would Increase Wealth Transfer Taxes in Family-Controlled Entities

The Internal Revenue Service (IRS) proposed regulations on August 2, 2016, under which transfers to family members of interests in family-controlled entities — including partnerships, limited liability companies (LLCs) and...more

Proposed regulations will significantly impact the valuation of interests in many family-controlled entities

by Dentons on

New rules have been proposed by the Internal Revenue Service (IRS) which would regulate the valuation of transfers of business interests between family members. Based upon recent interpretation, it appears that the IRS is...more

Valuation Discounts to Family-Controlled Entities in Peril Under Proposed IRS Regulations

by Varnum LLP on

On August 4, the Internal Revenue Service finally issued much anticipated proposed regulations under Section 2704 of the Internal Revenue Code, which regulations are intended to significantly limit taxpayers' ability to apply...more

Proposed Tax Regulations Limit Availability of Valuation Discounts to Family Business Owners

For family business owners who desire to transfer ownership of part of their business to the next generation, the valuation of the business interest is often an important factor to consider. This is especially true for family...more

IRS Proposes New Rules Designed to Restrict Valuation Discounts in Family Transfers

by McNair Law Firm, P.A. on

Partnerships and LLCs are common choices of entity for family-owned businesses, due to their flexibility and the many uses to which they can be put – including pooling of family assets, succession planning, asset protection,...more

Proposed Treasury Regulations Regarding Valuation Discounts for Transfers of Family-Controlled Entities, if Enacted, Would Apply...

by Dechert LLP on

After years of anticipation, the U.S. IRS recently issued Proposed Treasury Regulations that would, if enacted in their current form, substantially eliminate most valuation discounts for family-controlled entities and result...more

The End of Valuation Discounts in Estate Tax Planning?

Families with interests in closely held entities have long benefitted from reduced estate and gift tax exposure due to valuation discounts. If regulations proposed by the Internal Revenue Service are adopted in their present...more

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