News & Analysis as of

Estate Planning Gift Tax Valuation

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 -
Newburn Law

Agricultural Estate Planning: Securing Your Land's Future

Newburn Law on

In the world of farming and ranching, ensuring your land's future is vital. That's where agricultural estate planning comes in. It's all about smoothly transitioning your farm or ranch to the next generation, maintaining its...more

Greenbaum, Rowe, Smith & Davis LLP

The Implications for Estate Planning of Proposed Tax Provisions of the Build Back Better Act

What You Should Know •The House Ways and Means Committee has approved the tax provisions of President Biden’s Build Back Better Act, a significant first step towards passage. •If passed as drafted, the proposed...more

Moritt Hock & Hamroff LLP

Estate & Gift Tax Update: Build Back Better Act

On September 13, the House Ways and Means Committee released a proposed plan to pay for the $3.5 trillion Build Back Better Act (the “Act”). The proposed legislation contains a variety of changes across the tax code, but the...more

Schwabe, Williamson & Wyatt PC

Some Estate Planning and Business Transition Issues Not to Overlook Before 2021 Year-End

As we enter the final quarter of 2021, there are many things still to do and plan for before the end of the year. There are also some timing considerations given proposed legislative changes and the lead time needed to...more

Greenberg Glusker LLP

Transfers of Family-Controlled Business Entities to Family Members Could Get More Expensive

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Transfers of Family-Controlled Business Entities to Family Members Could Get More Expensive - The Internal Revenue Service (IRS) recently released proposed regulations that will dramatically change the valuation of...more

Butler Snow LLP

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

Butler Snow LLP on

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

Manatt, Phelps & Phillips, LLP

Proposed 2704 Regulations Attack Valuation Discounts

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

McNees Wallace & Nurick LLC

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

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

McAfee & Taft

Proposed IRS regulations will limit valuation discounts for family-held entities

McAfee & Taft on

On August 2, 2016, the Internal Revenue Service (IRS) released proposed regulations that, when finalized, will affect clients holding and transferring interests in family-controlled entities. Family limited partnerships...more

Farella Braun + Martel LLP

Proposed Section 2704 Regulations Would Impose Significant Restrictions on Valuation Discount Planning for Family Controlled...

High net worth families often utilize family entity structures, such as limited partnerships or limited liability companies, in order to provide for the coordinated management of family assets and move wealth to younger...more

K&L Gates LLP

IRS Plans to Disallow Minority Interest Discounts for Family-Controlled Entities; Action May Be Required Before Year-End

K&L Gates LLP on

Gifts and bequests of interests in family-owned companies have traditionally been valued at their fair market values for purposes of calculating the gift or estate tax on the transfer. In valuing these transfers, there is...more

Hinshaw & Culbertson LLP

Higher Taxes Projected for Transfer of Minority Interests in Hard to Value Assets

On August 2nd the U.S. Department of the Treasury announced proposed regulations to limit or possibly eliminate a strategy long utilized to reduce the fair market value of certain assets transferred during life or at death to...more

Cozen O'Connor

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

Cozen O'Connor on

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

McDermott Will & Emery

Proposed New IRS Rules for Valuing Interests in Family-Controlled Entities May Curb Discounts for Estate, Gift and...

In Depth - On August 2, 2016, the US Department of the Treasury issued long-awaited, proposed regulations on the valuation of interests in family-controlled entities for estate, gift and generation-skipping tax purposes....more

Gerald Nowotny - Law Office of Gerald R....

Double Down! - Inter-Generational Split Dollar Throws Sand in the Face of the IRS Again

Recently I wrote an article on JD Supra called Split to Be Tied (May 4, 2016) regarding the Tax Court decision in Estate of Morrissette, (Estate of Clara M. Morrissette v. Commissioner, 146 T.C. No. 11 (April 13, 2016)). Once...more

McGuireWoods LLP

Parties Settle Closely Watched Tax Court Cases Involving Defined Value Clause

McGuireWoods LLP on

The IRS and executors have settled two cases in the United States Tax Court involving members of the Woelbing family, who own Carma Laboratories, Inc., of Franklin, Wisconsin, the maker of Carmex skin care products, and a...more

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