News & Analysis as of

Closely Held Businesses Internal Revenue Service

Is It Debt Or Equity? Is It A Dividend Or Compensation? It Must Be A Closely Held Business

by Farrell Fritz, P.C. on

I had a call a couple of weeks ago from the owner of a business. His brother, who owned half of the business, owed some money to someone in connection with a venture that was unrelated to the business. The brother didn’t have...more

Have Your Business Do Onto You As You Would Have Your Business Do Onto Others (*)

by Farrell Fritz, P.C. on

Relationships are Hard- The well-being of a closely held business is based, in no small part, upon a number of relationships, including, for example, its dealings with customers, suppliers, service providers, employees,...more

IRS and Treasury Department to Withdraw Proposed Tax Regulations Curbing Valuation Discounts

by Davis Wright Tremaine LLP on

In a positive development for closely-held business owners and their families, the Treasury Department recently recommended the complete withdrawal of its proposed tax regulations that would have severely limited the...more

IRS and Treasury Department Announce Withdrawal of Proposed 2704 Regulations

by Tucker Arensberg, P.C. on

On October 4, 2017, in its Second Report to the President Identifying and Reducing Tax Regulatory Burdens the U.S. Department of the Treasury announced that it is recommending the complete withdrawal of the proposed 2704...more

Are you paying your children too much to work in the family business? The IRS might think so.

by Murtha Cullina on

A United States Tax Court recently issued a decision after trial that should serve as a reminder to management and controlling shareholders of family-owned businesses that salaries or other compensation paid to family-member...more

Reporting A Closely Held U.S. Corporation’s Overseas Activities

by Farrell Fritz, P.C. on

We have heard a lot about large, publicly-traded U.S. corporations that have parked trillions of dollars overseas to avoid the payment of U.S. income tax. We have heard how the tax system must be seriously broken to have so...more

Loans Between Related Entities

by Farrell Fritz, P.C. on

What Was Intended? Over the last thirty years, I have reviewed the income tax returns of many closely held corporations and partnerships. Quite often, on Schedule L (the balance sheet), I will see an entry for “other...more

2016 Year-End Estate Planning Advisory

by Katten Muchin Rosenman LLP on

In 2016, we continued to experience a period of relative stability in our federal transfer tax system and have been able to plan without expecting imminent significant changes to the system. Under the American Taxpayer Relief...more

Proposed Treasury Regulations on Valuation Discounts for Family-Controlled Entities

by White & Case LLP on

IRS Proposals Threaten Valuation Discounts for Family-Controlled Entities - The Treasury Department recently published new proposed regulations ("2704(b) regulations") which, if adopted in their current form, would...more

Estate Planning for Family Businesses

by GableGotwals on

Estate planning for closely held family businesses could be significantly affected by proposed regulations that have been published by the Internal Revenue Service. The IRS proposed regulations and their effect on...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

It's Time For Your Buy-Sell Checkup!

by Burr & Forman on

Shareholders, Partners and/or LLC members of any closely-held or family-held company should check the buy-sell formula contained in their Shareholder Agreement (sometimes called a Buy-Sell Agreement), Partnership Agreement or...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 changes to Section 2704 could spur tax increase for owners of closely held businesses

by Thompson Coburn LLP on

Controversial proposed regulations issued by the Treasury and the IRS on August 4, 2016, would change rules for valuing interests in business entities of which a person or a family owns at least one-half. The regulations...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

IRS Proposes Regulations to Limit Valuation Discounts for Family Businesses

On August 2, 2016, the Internal Revenue Service and the Treasury Department issued proposed regulations intended to substantially limit the use of discounts in valuing intra-family transfers of interests in family-controlled...more

Valuation Discounts for Intra-Family Transfers of Family-Held Business Interests are Proposed to be Curtailed – Act Now!

by Taylor English Duma LLP on

On August 4, 2016, the Treasury Department issued proposed regulations that would, if implemented, significantly curtail valuation discounts applied to intra-family transfers of family business interests. Final adoption of...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

Proposed Regulations Under Internal Revenue Code Section 2704: Changes May Be Coming to Transfers of Closely Held Business...

On August 2, 2016, the Treasury Department issued proposed regulations under the authority provided in Section 2704(b) of the Internal Revenue Code (the "Code"). These proposed regulations were much anticipated by the estate...more

The End of Valuation Discounts in Estate Tax Planning?

by Bilzin Sumberg on

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

Family-Controlled Businesses -- Tax Targets Again: Newly Proposed 2704 Regulations and Presidential Candidates' Positions

by Burr & Forman on

It's August of an election---year, and not just any election---year, a presidential election year. So, in less than 80 days, we'll all go to the polls and elect a new president. While Benjamin Franklin might have been right...more

The End to Discounts for Transfers of Interests in Family Business Entities

by Dickinson Wright on

The ability to use transfer and liquidation restrictions in legal documents to reduce the value of an interest in a family-controlled (or “closely-held”) business entity (e.g., partnership, corporation, limited liability...more

Proposed Treasury Regulations Would Severely Limit Valuation Discounts

by Holland & Knight LLP on

Earlier this month, the U.S. Department of the Treasury unveiled its long-awaited proposed regulations targeting valuation discounts commonly used in estate planning, thereby overturning decades of settled law. As drafted,...more

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