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Business Succession Planning – Should I Own My Business In A Trust?

Closely-held businesses come in all shapes and sizes. Some owners own 100% of their businesses. Some have partners. Some have children in the business. Some do not. A common question that a client asks the business and...more

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

The IRS has withdrawn the controversial proposed regulations under Code §2704 that would have significantly affected the use of discounts in US estate planning.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 Issues Proposed Regulations Under Code §2704 Impacting Gift and Estate Taxes

The IRS has at last issued long-anticipated proposed regulations under Code §2704. We perceive the proposed regulations as an attempt by the IRS to curtail the use of discounts – such as minority interest and lack of...more

Family Limited Partnerships: Are Discounts Disappearing?

“Family limited partnerships” – that is, family investment entities usually structured as LLCs or limited partnerships – have been a popular estate planning technique for years. Generally speaking, a client can transfer...more

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