Once Removed Episode 19: The Step-Transaction Doctrine and the Case of Smaldino
Once Removed Episode 18: The Reciprocal Trust Doctrine
Charitable Planning With Guest Stephanie Hood: Navigating Complex Rules and Traps for the Unwary
Once Removed Episode 16: Gift and Estate Tax, Inflation Adjustments for 2024
Once Removed Episode 17: Annual Gifting to Individuals: Options, Opportunities and Pitfalls
Once Removed Episode 12: SLATs and the Case of McKim vs. McKim
Once Removed Episode 11: Spousal Lifetime Access Trusts, or SLATs
Once Removed Episode 10: Trustee Removal and Case Update on Leo Kahn Revocable Trust
(A)ESOP's Fables - The Income and Estate Tax-Free ESOP
The Renoir Spelling Bee
Taking the Sting Out of Death Taxes with Dylan Metzner, Jones & Keller
RETURN TO FOREVER - What Game Shall We Play Today?
To Give or Not to Give: Considerations for Year-End Gifting
INTRODUCING MALTA SPLIT DOLLAR
THE PAPER CHASE
With a Little Help from My Friends
The Greatest Gift: Your Individual + Family Estate Plan
As a family business owner, are you missing out on valuable estate and wealth transfer planning opportunities or jeopardizing your current plan altogether? Katten recently hosted a program that addressed common concerns,...more
Not Selling Your Business This Year? Beginning shortly before the House Ways and Means Committee released its version of the President’s Build Back Better plan, several posts on this blog have explored the uptick in M&A...more
Today’s historically low interest rates and depressed asset values make this an excellent time to engage in various estate planning techniques. Current conditions present several planning opportunities for transferring wealth...more
Wineries and vineyards are unique assets to consider when crafting personal financial, estate and business succession plans for clients, both of which are crucial components of wealth management....more
• The U.S. House of Representatives and Senate ushered H.R. 1, the Tax Cuts and Jobs Act (the Act), through conference committee, and President Donald Trump signed the Act into law on Dec. 22, 2017. • Most of the Act's...more
In September, we posted a blog discussing the Treasury Department’s issuance of proposed regulations under Section 2704 of the Internal Revenue Code (sometimes referred to as the 2704 proposed regulations) that could...more
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
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
On Aug. 2, 2016, the Treasury Department and the Internal Revenue Service released proposed regulations under Internal Revenue Code (Code) section 2704 (the “Proposed Regulations”). The Proposed Regulations, if finalized in...more
INTRODUCTION - There are over five million family owned businesses operating in the United States.1 The Small Business Administration has indicated that over 90% of all businesses operating in North America are family...more
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
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
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
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
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
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
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
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
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
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
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
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
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
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
The federal government proposed sweeping new tax rules earlier this month that would dramatically affect family businesses, investment partnerships and other entities. These rules, which have been widely reported, would...more