News & Analysis as of

Internal Revenue Code (IRC) Closely Held Businesses Estate Planning

Rivkin Radler LLP

Transferring the Family Business To A Private Foundation? Are You Sure About That?

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Charitable organizations are dependent, in no small part, upon the financial support of many successful business owners. The generosity of these individuals and their organizations may be a manifestation of several factors...more

Cole Schotz

Death, Taxes and Shareholder Agreements: Lessons from the Connelly Case

Cole Schotz on

Recently, the U.S. Supreme Court ruled unanimously in Connelly v. United States, that the valuation of a decedent’s shares in a closely held corporation for federal estate tax purposes must include insurance proceeds received...more

DarrowEverett LLP

How Will New Congress Impact Tax and Estate Planning Strategies?

DarrowEverett LLP on

With the looming elections, tax planners have taken time to consider what the future of Estate and Gift Tax planning might be under the new Congress. Every new Congress considers changes to the Internal Revenue Code of 1986,...more

Husch Blackwell LLP

Unanimous Supreme Court Determines Company-Owned Life Insurance Increases Fair Market Value

Husch Blackwell LLP on

On June 6, 2024, the Supreme Court held 9-to-0 in Connelly v. United States that company-owned life insurance increases the company’s fair market value for estate tax purposes, and the company’s obligation to redeem a...more

Rivkin Radler LLP

BEWARE: Redemption Agreement Funded with Corporate-Owned Life Insurance

Rivkin Radler LLP on

On June 6, 2024, in the case of Connelly v. United States, the United States Supreme Court determined that corporate-owned life insurance proceeds used to redeem a decedent’s shares in the corporation must be included when...more

ArentFox Schiff

US Supreme Court Affirms the Eighth Circuit’s Decision in Favor of the Government Concerning the Estate Tax Treatment of Life...

ArentFox Schiff on

In Connelly v. US, 602 US ___ (6/6/2024), the US Supreme Court affirmed a decision of the US Court of Appeals for the Eighth Circuit in favor of the government concerning the estate tax treatment of life insurance proceeds...more

Rivkin Radler LLP

Transferee Liability for Estate Tax: The Downside of Being a Beneficiary

Rivkin Radler LLP on

Death of a Parent- In the context of a family-owned business, it is often the case that the matriarch or patriarch of the family is also the chief executive of the business. They may have founded the business, or they may...more

Adler Pollock & Sheehan P.C.

Family Businesses Would Be Wise To Consider IRC Section 6166

It’s true that because of the current record-high gift and estate tax exemption amount, most families don’t have to worry about transfer taxes. However, there are high net worth individuals who must continue to work to reduce...more

Katten Muchin Rosenman LLP

2016 Year-End Estate Planning Advisory

In 2016, we continued to experience a period of relative stability in our federal transfer tax system and have been able to plan without expecting imminent significant changes to the system. Under the American Taxpayer Relief...more

Foster Garvey PC

Closely Held Family Entities in Grave Danger: Minority Interest and Lack of Marketability Discounts About to Disappear?

Foster Garvey PC on

After years of slow boiling anticipation, statements made by the IRS and the Treasury this year heated up the conjecture and anticipation which finally came to a head on August 2, 2016. I’m of course talking about the...more

Proskauer Rose LLP

Personal Planning Strategies - August 2016

Proskauer Rose LLP on

Low Interest Rates Yield Wealth Transfer Opportunities - Low interest rates can create wealth transfer opportunities. For various wealth transfer techniques, the IRS assumes that a certain minimum interest rate is in...more

Blank Rome LLP

Anticipated IRS Regulations May Impact Discounts On Intra-Family Transfers of Closely Held Business Interests

Blank Rome LLP on

Action Item: It is anticipated that Treasury will soon issue new regulations that will affect the valuation discounts applicable to intra-family transfers of interests in closely held entities. It may be advisable to review...more

Adler Pollock & Sheehan P.C.

Estate tax relief for family businesses

If a substantial portion of a person’s wealth is tied up in a family or closely held business, he or she may be concerned that the estate will lack sufficient liquid assets to pay estate taxes. If that’s the case, heirs may...more

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