News & Analysis as of

IRC Section 2704

Treasury Withdraws Problematic Section 2704 Discount Regulation

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

Treasury to Withdraw Proposed IRC §2704 Regulations

by Bryan Cave on

The Department of the Treasury has withdrawn the controversial proposed regulations for Section 2704 of the Code. Section 2704 limits valuation discounts in family-controlled entities for certain lapsing rights and...more

Private Wealth Updates - Fall 2017

by Arnall Golden Gregory LLP on

The gift tax annual exclusion will increase from $14,000 to $15,000 next year, allowing donors to give up to $15,000 ($30,000 combined for married couples) per donee each year without incurring gift tax or using lifetime gift...more

IRS Withdraws Proposed Code §2704 Regulations On Lapsing Rights And Restrictions

by Cole Schotz on

The IRS has withdrawn the controversial proposed regulations under Code §2704 that would have significantly affected the use of discounts in US estate planning. Code §2704 provides that certain “applicable restrictions” on...more

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

by Davis Wright Tremaine LLP on

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

Treasury to Withdraw Controversial Section 2704 Proposed Regulations

by Baker Donelson on

The Treasury Department announced on October 2, 2017 that it plans to withdraw proposed regulations under I.R.C. Section 2704 ("Proposed 2704 Regulations") that would have reduced or eliminated certain valuation discounts for...more

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

In September and December of last year, we posted blog articles discussing the Treasury Department’s issuance of proposed regulations under Section 2704 of the Internal Revenue Code (sometimes referred to as the 2704 proposed...more

Treasury Withdraws Proposed Regulations Aimed at Minimizing Valuation Discounts

by McDermott Will & Emery on

Proposed section 2704 regulations were withdrawn in regulatory review ordered by President Trump....more

Proposed Section 2704 Regulations to be Withdrawn

by Butler Snow LLP on

Remember all that time and energy you put into figuring out what the proposed regulations under Section 2704 were all about? Well, you’re going to want to try to find a way to get that back. The proposed regulations, the...more

Ding, Dong, the Witch is Dead

by Charles (Chuck) Rubin on

--Here lies the remains of the Code §2704 Proposed Regulations. RIP, 2016-2017-- As part of President Trump’s mandated review of federal regulations, the Secretary of Treasury has issued a report specifically recommending...more

IRS and Treasury Department Announce Withdrawal of Proposed 2704 Regulations

by Tucker Arensberg, P.C. on

On October 4, 2017, in its Second Report to the President Identifying and Reducing Tax Regulatory Burdens the U.S. Department of the Treasury announced that it is recommending the complete withdrawal of the proposed 2704...more

Treasury Plans to Pull Unpopular Discount Regulation

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

Treasury To Repeal/Revise 8 Burdensome Regs

As previously discussed, the IRS and Treasury identified in July eight Obama era tax regulations that are burdensome on taxpayers. The next step for Treasury was to determine what to do with these regulations, and today we...more

Treasury Plans to Pull Unpopular Discount Regulation

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

IRS Regulations on the Chopping Block

by Charles (Chuck) Rubin on

Tax practitioners have complained for years about the ever-expanding scope and complexity of both the Internal Revenue Code and Treasury Regulations. A possible shrinkage in the Treasury Regulations may soon occur....more

Proposed Regulations Limiting Discounts on Family Gifts Targeted for Reform

Last summer, we discussed the IRS’s issuance of new Proposed Regulations under Section 2704 of the Internal Revenue Code, which regulations would severely impact discounts on gifts made to family members. ...more

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

by 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

The Future Of Proposed IRS § 2704 Modifications Is Uncertain

Proposed changes to Internal Revenue Code (IRC) § 2704, which would impact the valuation of transfers of family business interests at death, come at an interesting time politically given the Trump Administration’s desire to...more

KNOWN UNKNOWNS about Federal Tax Laws and Regulations

by Dickinson Wright on

The new administration in Washington, supported by Republican majorities in Congress, has pledged substantial changes to federal tax laws and regulations. One change may - or may not - be the complete elimination of federal...more

A Reprieve from Proposed Regulations Related to Valuation of Family Businesses?

In December, we posted a blog discussing a much anticipated hearing held on the Treasury Department’s issuance of proposed regulations under Section 2704 of the Internal Revenue Code (sometimes referred to as the 2704...more

Treasury Department Unofficial Statements on Proposed Section 2704 Regulations

by Charles (Chuck) Rubin on

There is a lot of uncertainty whether the Section 2704 proposed regulations will ever be finalized, either due to policy to be set by President-elect Trump, and/or Congressional efforts to block those regulations....more

Ron Aucutt’s “Top Ten” Estate Planning and Estate Tax Developments of 2016

by McGuireWoods LLP on

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

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

Personal Planning Strategies - December 2016

by Proskauer Rose LLP on

2017 Estate, Gift and GST Tax Update: What This Means for Your Current Will, Revocable Trust and Estate Plan - As we previously reported, the American Taxpayer Relief Act of 2012 (the "Act") made the following permanent:...more

What Proposed Tax Plans by Trump Administration and House Republicans Mean for Personal Planning

by Perkins Coie on

The election of Donald Trump and Republican majorities in U.S. Congress make the future of the federal transfer tax system (gift, estate and generation-skipping transfer (GST) taxes) uncertain. President-elect Trump and...more

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