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
In response to Internal Revenue Code Section 2001(g)(2), enacted as part of the 2017 Tax Act, in which the Secretary of the Treasury was directed to prescribe regulations to carry out IRC Section 2001(g) with respect to the...more
As previously discussed, the IRS and Treasury identified in July eight Obama era tax regulations that are burdensome on taxpayers. In early October, Treasury announced that it proposed to repeal or revise these regulations. ...more
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
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
The U.S. Department of the Treasury announced on July 7, 2017, in Notice 2017-38 (the Notice) that it has identified as "significant tax regulations" eight sets of U.S. federal tax regulations that were issued between Jan. 1,...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
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
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 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
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
On August 2, 2016 the U.S. Treasury Department issued proposed regulations addressing transfers between family members of interests in family-controlled entities (e.g., corporations, partnerships and LLCs). If enacted, these...more
On Aug. 2, 2016, the Treasury Department issued proposed regulations on valuation discounts. These proposed regulations make sweeping changes to the valuation rules for family-owned entities. If the proposed regulations...more
The Department of the Treasury wants to place limitations on valuation discounts that are currently commonly used to reduce asset values in family-owned and closely-held businesses, in an effort to increase tax revenue. The...more
IRS regulations anticipated for release as early as this September may further restrict valuation discounts. The exact scope of the regulations is unknown, but the regulations will likely make it more difficult for taxpayers...more
Recent comments by Cathy Hughes, an Estate and Gift Tax Attorney Advisor in the Office of Tax Policy at the U.S. Treasury Department, indicated that the department may issue proposed regulations as early as September 2015...more