FLPs and Other “Discounting” Strategies: Targets for IRS Scrutiny? Act Now!

Alston & Bird
Contact

Proposed regulations issued by the Treasury Department in August 2016 under Section 2704 of the Internal Revenue Code seek to limit valuation discounts afforded by family limited partnerships (FLP) and other common planning techniques. The combination of a $5.45 million federal estate and gift tax exemption for individuals plus “exemption portability” rules allowing a deceased spouse’s unused exemption to pass to his or her surviving spouse shield most estates from federal estate and gift taxes. But such taxes are still a major concern to high-net-worth individuals and families because of the 40% tax rate that applies once exclusions have been fully utilized. Thoughtful advance planning is necessary to avoid additional estate and gift tax liability should the proposed regulations become final.

Please see full publication below for more information.

LOADING PDF: If there are any problems, click here to download the file.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Alston & Bird | Attorney Advertising

Written by:

Alston & Bird
Contact
more
less

PUBLISH YOUR CONTENT ON JD SUPRA NOW

  • Increased visibility
  • Actionable analytics
  • Ongoing guidance

Alston & Bird on:

Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide
- hide