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Estate Tax Family Businesses U.S. Treasury

Estate taxes, also known as inheritance or death taxes, are taxes on an individual's right to transfer property at death.
Stinson LLP

IRS Eliminates Worry About "Clawback"

Stinson LLP on

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

Lowndes

Treasury Withdraws Problematic Section 2704 Discount Regulation

Lowndes on

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

Davis Wright Tremaine LLP

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

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

Lowndes

Treasury Plans to Pull Unpopular Discount Regulation

Lowndes on

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

Holland & Knight LLP

Treasury Dept. Identifies 8 "Significant Tax Regulations" for Review to Reduce Burden

Holland & Knight LLP on

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

Bradley Arant Boult Cummings LLP

Update On Proposed Tax Regulations Affecting Availability of Valuation Discounts to Family Business Owners

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

Bradley Arant Boult Cummings LLP

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

Burr & Forman

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

Burr & Forman 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

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

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

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

Goulston & Storrs PC

Proposed Rules Would Limit Valuation Discounts for Family Controlled Entities

Goulston & Storrs PC on

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

Troutman Pepper

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

Troutman Pepper on

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

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

Ballard Spahr LLP on

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

Coblentz Patch Duffy & Bass

Proposed Treasury Regulations To Affect Family Wealth Transfers

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

Lathrop GPM

Treasury Department Issues Proposed Regulations on Valuation Discounts

Lathrop GPM on

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

Lewitt Hackman

Game Changer? Succession Planning Targeted by IRS

Lewitt Hackman on

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

BakerHostetler

IRS Plans to Further Restrict Family Business Valuation Discounts

BakerHostetler on

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

Holland & Knight LLP

New Treasury Regulations May Limit Transfer Tax Savings

Holland & Knight LLP on

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

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