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Estate Planning › Gift Tax › IRC Section 2704

Estate Planning is a process where individuals prepare or plan for the settlement of their personal affairs in the event of incapacitation or death. Estate plans typically include provisions relating to the... more +
Estate Planning is a process where individuals prepare or plan for the settlement of their personal affairs in the event of incapacitation or death. Estate plans typically include provisions relating to the disposition of assets, guardianship of minor children, and appointment of representatives to make medical and financial decisions. Effective estate planning can decrease tax liability and facilitate the probate process.  less -
Arnall Golden Gregory LLP

Private Wealth Updates - Fall 2017

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The gift tax annual exclusion will increase from $14,000 to $15,000 next year, allowing donors to give up to $15,000 ($30,000 combined for married couples) per donee each year without incurring gift tax or using lifetime gift...more

Cole Schotz

IRS Withdraws Proposed Code §2704 Regulations On Lapsing Rights And Restrictions

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The IRS has withdrawn the controversial proposed regulations under Code §2704 that would have significantly affected the use of discounts in US estate planning. Code §2704 provides that certain “applicable restrictions” on...more

Butler Snow LLP

Proposed Section 2704 Regulations to be Withdrawn

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Remember all that time and energy you put into figuring out what the proposed regulations under Section 2704 were all about? Well, you’re going to want to try to find a way to get that back. The proposed regulations, the...more

Lowndes

Treasury Plans to Pull Unpopular Discount Regulation

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As discussed earlier this summer, Treasury and the IRS identified as a burdensome regulation the Proposed Regulations under Section 2704 of the Internal Revenue Code, which regulations would severely impact discounts on gifts...more

Lowndes

Treasury Plans to Pull Unpopular Discount Regulation

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As discussed earlier this summer, Treasury and the IRS identified as a burdensome regulation the Proposed Regulations under Section 2704 of the Internal Revenue Code, which regulations would severely impact discounts on gifts...more

Lowndes

Proposed Regulations Limiting Discounts on Family Gifts Targeted for Reform

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Last summer, we discussed the IRS’s issuance of new Proposed Regulations under Section 2704 of the Internal Revenue Code, which regulations would severely impact discounts on gifts made to family members. ...more

McGuireWoods LLP

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

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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

Proskauer Rose LLP

Personal Planning Strategies - December 2016

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2017 Estate, Gift and GST Tax Update: What This Means for Your Current Will, Revocable Trust and Estate Plan - As we previously reported, the American Taxpayer Relief Act of 2012 (the "Act") made the following permanent:...more

Perkins Coie

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

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

Jackson Walker

Time to Transfer Early Stage Investments?

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

Bradley Arant Boult Cummings LLP

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

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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

Burr & Forman

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

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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

Dechert LLP

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

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

Burr & Forman

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

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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

Butler Snow LLP

Owners of Family Controlled Entities Must Act Quickly in Light of New IRS Regulations Attacking Valuation Planning

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Chapter 14 of the Internal Revenue Code consists of four Code Sections (Sections 2701 – 2704) designed to close valuation loopholes. Prior to Congress’s enactment of Chapter 14 in 1990, estate planners had a host of tools...more

Dickinson Wright

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

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

Holland & Knight LLP

Proposed Treasury Regulations Would Severely Limit Valuation Discounts

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

Manatt, Phelps & Phillips, LLP

Proposed 2704 Regulations Attack Valuation Discounts

Manatt, Phelps & Phillips, LLP on

The IRS has expanded the scope of IRC Section 2704 by issuing proposed regulations that seek to limit the availability of valuation discounts for transfers of interests in family-controlled entities. In general, the purpose...more

Goulston & Storrs PC

Proposed Rules Would Limit Valuation Discounts for Family Controlled Entities

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On August 2, 2016, the Internal Revenue Service proposed regulations that would severely limit valuation discounts for lack of marketability and lack of control that taxpayers have historically applied for federal gift,...more

Stinson LLP

IRS Proposes Rules That Would Dramatically Reduce Valuation Discounts in Family Business Succession Planning

Stinson LLP on

Business Owners May Have Little Time to Act Before Rules Are Finalized - The valuation of a family member's interest in a family business has a major impact on the success or failure of a transfer of such interest to...more

McNees Wallace & Nurick LLC

IRS Proposes New Rules for Valuing Interests in Family-Owned Businesses

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Earlier this month, the IRS issued long-awaited proposed regulations under Section 2704 of the Internal Revenue Code that, if adopted, will have a substantial impact on traditional estate planning techniques commonly utilized...more

Troutman Pepper

IRS Proposes New Regulations That Will Significantly Limit the Use of Valuation Discounts on Transfers of Interests in Closely...

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The proposed regulations disregard restrictions that have been used by valuation experts and acknowledged by the courts to reduce valuations. If you are an owner of a closely held entity, recently proposed Treasury...more

Pillsbury Winthrop Shaw Pittman LLP

Proposed Section 2704 Regulations

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On August 2, 2016, the Treasury Department released proposed regulations amending and expanding upon the current regulations to Internal Revenue Code Section 2704. The proposed regulations, if adopted, would affect the...more

Ballard Spahr LLP

Proposed IRS Rules Endanger Business Valuation Discounts for Family-Owned Entities

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Historically, the IRS has closely scrutinized transfers of interests in family-owned entities between family members. In particular, it has sought to curtail the use of discounts to decrease the estate and gift tax value of...more

Cozen O'Connor

IRS Proposed Regulations Attack Valuation Discounts for Family Transfers — The Clock Is Now Ticking

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The U.S. Department of the Treasury and the IRS have just issued anticipated proposed regulations that, if made final, would severely limit the ability of taxpayers to transfer interests in family limited partnerships and...more

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