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Internal Revenue Service Family Limited Partnerships

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Kohrman Jackson & Krantz LLP

Unlocking Tax Savings: Family Limited Partnerships in Estate Planning

As Trump era estate tax cuts are likely coming to an end in 2025, wealthy business owners are increasingly utilizing Family Limited Partnerships (FLPs) to significantly save the family taxes when they are gone....more

Katten Muchin Rosenman LLP

Keep It in the Family: Three Tips for Preserving Family Business Interests

As a family business owner, are you missing out on valuable estate and wealth transfer planning opportunities or jeopardizing your current plan altogether? Katten recently hosted a program that addressed common concerns,...more

Farrell Fritz, P.C.

The Threat Of Higher Taxes, & The Sirens’ Song Of Tax-Saving Schemes

Farrell Fritz, P.C. on

What a Mess- A “perfect storm” may be defined as a critical state of affairs arising from the convergence of a number of negative factors, often after the unexpected introduction of some catalytic event. The situation...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Nelson v. Commissioner, T.C. Memo 2020-81: Further Insights into the Valuation of Hard-to-Value Assets

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 LLP

2019 Estate and Tax Planning Newsletter

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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

Bradley Arant Boult Cummings LLP

Recent Rulings on “Family Limited Liability Entity” Election Create Traps for the Unwary

Although every LLC, limited partnership or other pass-through entity doing business in Alabama, and even those simply organized under Alabama law, are subject to an annual business privilege tax (BPT), certain entities can...more

Clark Hill PLC

BEWARE! Impact of New Tax Rules on Your Family Limited Partnership

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Family limited partnerships (“FLPs”) are a common estate planning technique. They permit centralized asset management, provide liability protection, and create a mechanism by which one generation can transfer wealth to the...more

McGuireWoods LLP

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

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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

BakerHostetler

Beyer Beware: An Examination of a Family Limited Partnership Gone Wrong

BakerHostetler on

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

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

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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

Perkins Coie

Federally Proposed Rules to Increase Tax Cost of Family-Entity Transfers

Perkins Coie on

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

Cozen O'Connor

IRS Proposed Regulations Attack Valuation Discounts for Family Transfers — The Clock Is Now Ticking

Cozen O'Connor on

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

Adler Pollock & Sheehan P.C.

Insight on Estate Planning - February/March 2016

When interest rates are low, it’s high time for estate planning - Interest rates remain at record lows, and while many experts believe they’ll begin to rise soon, it’s likely they’ll rise slowly. So it’s an ideal time to...more

Best Best & Krieger LLP

Best in Law: IRS Moves Mean It's Time to Shift Family Entity Wealth

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

Troutman Pepper

The Time to Transfer Entity Interests Is Now - Trust and Estates Update Vol. 2015, Issue 1

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Upcoming IRS regulations may significantly limit and reduce planning opportunities to transfer minority interests in closely held entities to family members and increase the transfer tax cost associated with moving such...more

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