News & Analysis as of

Internal Revenue Service Limited Liability Company (LLC) Family Businesses

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.  
ArentFox Schiff

What Private Companies and Family Offices Need to Consider in 2025

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Across all industries, private companies, family offices, and their owners and management teams face rapidly evolving challenges, opportunities, and risks in the dynamic environment that is 2025. Here are 11 issues that...more

Rivkin Radler LLP

Transfers Within the Family Business: Gifts or “Ordinary Course” Transactions?

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It is not uncommon, in the context of a business entity in which a family owns a controlling or substantial interest, for an adviser to encounter intersecting gift and income tax issues. This week’s post will consider one...more

Rivkin Radler LLP

The Family-Owned Business, Stock Options, And Personal Goodwill – a Smorgasbord of Tax Issues

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Many of us have encountered variations of the following scenario: a parent owns and operates a business; one or more of their children are employed in the business; as the children mature and become more experienced and...more

Rivkin Radler LLP

Deferring the Tax Hit on a Grant Equity to an Employee – Are You Prepared to Enforce the Forfeiture Provision?

Rivkin Radler LLP on

“Would I ever leave this company? Look, I’m all about loyalty. In fact, I feel like part of what I’m being paid for here is my loyalty. But if there were somewhere else that valued loyalty more highly, I’m going wherever they...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

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

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

Burr & Forman

It's Time For Your Buy-Sell Checkup!

Burr & Forman on

Shareholders, Partners and/or LLC members of any closely-held or family-held company should check the buy-sell formula contained in their Shareholder Agreement (sometimes called a Buy-Sell Agreement), Partnership Agreement or...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

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 Locke

IRS Proposes New Regulations That Will Significantly Limit the Use of Valuation Discounts on Transfers of Interests in Closely...

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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

McAfee & Taft

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

McAfee & Taft on

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

Ballard Spahr LLP

Proposed IRS Rules Endanger Business Valuation Discounts for Family-Owned Entities

Ballard Spahr LLP on

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

Lewitt Hackman

Game Changer? Succession Planning Targeted by IRS

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The Department of the Treasury wants to place limitations on valuation discounts that are currently commonly used to reduce asset values in family-owned and closely-held businesses, in an effort to increase tax revenue. The...more

Neal, Gerber & Eisenberg LLP

IRS Proposes Regulations That Would Eliminate Most Valuation Discounts for Transfers of Interests in Family Entities

The Internal Revenue Service (IRS) released regulations on August 2, 2016 that would limit the use of discounts when valuing interests in family entities for estate, gift and generation-skipping transfer tax purposes. If...more

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