Once Removed Episode 19: The Step-Transaction Doctrine and the Case of Smaldino
Once Removed Episode 18: The Reciprocal Trust Doctrine
Once Removed Episode 16: Gift and Estate Tax, Inflation Adjustments for 2024
Once Removed Episode 17: Annual Gifting to Individuals: Options, Opportunities and Pitfalls
Taking the Sting Out of Death Taxes with Dylan Metzner, Jones & Keller
Gift Tax Basics
NGE On Demand: GRAT Trusts with Eric Mann
To Give or Not to Give: Considerations for Year-End Gifting
ATTENTION ALL CADETS!
If you are a high-net worth individual, 2020 may be the time to take advantage of the opportunity created under a confluence of low applicable federal rates, valuation opportunities, and the temporarily increased Unified...more
Nelson v. Commissioner is a recent gift tax case where the IRS challenged the value of the gift and sale of limited partnership interests to a trust created for the beneficial interest of the taxpayer’s family members. In...more
Blank Rome’s annual estate and tax planning newsletter addresses estate planning concepts and techniques that should be considered in 2019 by our clients and friends. 1. Transfer Taxes. The major changes made in 2010 in...more
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
The opinion issued on Sept. 29, 2016, in the case of Estate of Edward G. Beyer v. Commissioner of Internal Revenue was the culmination of an estate planning exercise that had an unfortunate ending for everyone involved (other...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
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
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
The IRS may take action very soon to eliminate or reduce a widely used and valuable family business entity wealth transfer strategy. The window of opportunity to take advantage of this strategy may close within the next month...more
Blank Rome’s annual estate planning newsletter discusses certain concepts and techniques that we hope may be of interest to our clients and friends....more
In This Issue: - To preserve your wealth, consider a DAPT - Estate planning for same-sex spouses: What the Supreme Court’s DOMA ruling means - Using an FLP or LLC? Beware the step transaction doctrine ...more