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Family Businesses Internal Revenue Code (IRC) Estate Planning

DarrowEverett LLP

Business Succession Planning: Pros and Cons of Passing S Corp Shares in Trust

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Business succession planning and estate planning are often linked together, particularly in the case of closely held family businesses. In the case of a shareholder who wishes to pass along their shares of an S corporation as...more

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

Rivkin Radler LLP

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

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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

Stinson LLP

IRS Eliminates Worry About "Clawback"

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In response to Internal Revenue Code Section 2001(g)(2), enacted as part of the 2017 Tax Act, in which the Secretary of the Treasury was directed to prescribe regulations to carry out IRC Section 2001(g) with respect to the...more

McGuireWoods LLP

Estate Tax Changes Past, Present and Future

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I. INTRODUCTION - This outline is a selective and evolving review of the history of the modern federal estate tax. It originated during the attempts to repeal the estate tax in President Clinton’s second term and...more

Adler Pollock & Sheehan P.C.

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

Perkins Coie

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

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

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

Troutman Pepper Locke

Disappearing Discounts?: IRC 2704 Proposed Regulations Threaten Valuation Discounts for Transfers of Interests in...

Troutman Pepper Locke on

Purpose of Section 2704 - Internal Revenue Code Section 2704 was originally passed to restrict certain types of valuation discounts on transfers of ownership interests in family-owned businesses among family members....more

McNees Wallace & Nurick LLC

IRS Proposes New Rules for Valuing Interests in Family-Owned Businesses

Earlier this month, the IRS issued long-awaited proposed regulations under Section 2704 of the Internal Revenue Code that, if adopted, will have a substantial impact on traditional estate planning techniques commonly utilized...more

McAfee & Taft

Proposed IRS regulations will limit valuation discounts for family-held entities

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On August 2, 2016, the Internal Revenue Service (IRS) released proposed regulations that, when finalized, will affect clients holding and transferring interests in family-controlled entities. Family limited partnerships...more

Farella Braun + Martel LLP

Proposed Section 2704 Regulations Would Impose Significant Restrictions on Valuation Discount Planning for Family Controlled...

High net worth families often utilize family entity structures, such as limited partnerships or limited liability companies, in order to provide for the coordinated management of family assets and move wealth to younger...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

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

Blank Rome LLP

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

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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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