FLPs Remain a Viable Intra-Family Transfer Option, But Act Now The Internal Revenue Service has floated the idea of making regulatory changes to the implementation of section 2704, in this article the author gives us an update on the subject and underscores the need to facilitate intra-family transfers of businesses. ...

The IRS is Challenging the Appropriateness of Discounts when Preparing a Valuation The current regulations, Revenue-Ruling 93-12, allow for discounts when valuing a Family Limited Partnership (FLP). The proposal is expected to potentially limit the allowed discount and consequently raise the taxable portion of the trust or estate structures. This article reviews the current requirements for FLPs, their hist ...

Use of Synthetic Credit Ratings to Determine the Appropriate Market Yield for the Preferred Equity Interest Among the estate tax planning methods that include grants of “carried” or profit interests, grantor retained annuity trusts, outright gifts, etc., entity freeze is a less known, or perhaps, less utilized tool. Yet, in certain circumstances, a freeze entity can be a compelling wealth transfer mechanism ...