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Valuation Internal Revenue Service Estate Tax

Levenfeld Pearlstein, LLC

Redemption Agreements and Life Insurance Proceeds: What the SCOTUS Decision in Connelly Means for Closely Held Businesses

Many closely held businesses have shareholder buy/sell redemption agreements. These agreements are critical to maintaining business continuity when a key shareholder exits the company. When the redemption agreement is...more

Foster Swift Collins & Smith

Business Owners: How to Avoid Additional Estate Taxes after Connelly v. Commissioner

In early June, the Supreme Court issued an opinion that clarifies how company-owned life insurance impacts the value of the company for estate tax purposes. As a business owner, you may need to re-evaluate the use of those...more

Dinsmore & Shohl LLP

Connelly Decision: Supreme Court Rules Company-Owned Life Insurance Must Be Included in Estate Valuation

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A recent Supreme Court decision means that owners of closely held companies with company-owned life insurance policies should take extra precautions to avoid an unexpectedly large estate tax bill from the IRS....more

Lathrop GPM

Supreme Court Confirms Life Insurance Proceeds Received by Corporation Increase Estate Tax Value of Decedent’s Shares

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The June 6 unanimous ruling by the United States Supreme Court in Connelly v. United States creates a significant change for closely held businesses planning to utilize life insurance proceeds to fund buy-sell agreements....more

Kohrman Jackson & Krantz LLP

Unlocking Tax Savings: Family Limited Partnerships in Estate Planning

As Trump era estate tax cuts are likely coming to an end in 2025, wealthy business owners are increasingly utilizing Family Limited Partnerships (FLPs) to significantly save the family taxes when they are gone....more

Rivkin Radler LLP

Estate, Gift, GST & Related Income Tax Proposals – What is the White House Doing?

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Earlier this week the White House released its Fiscal Year 2025 Budget. Of course, the federal government has not yet adopted a budget for the Fiscal Year 2024 even as we approach that year’s halfway mark. But I digress. The...more

Rivkin Radler LLP

One Step Closer to “Building Back” – Where Do Federal Transfer Taxes Stand?

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Tax the Rich? The President’s plan for a tax regime that would ensure the rich pay their “fair share” of the cost of implementing his programs has come one step closer to being realized . . . maybe . . . well, sort of ....more

Rivkin Radler LLP

Gifts, Sales and Effective Dates: The Race Against the Clock the Taxpayer Cannot See

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It was quite a week, wasn’t it?- Manchin- Senator Manchin continued to attract a lot of attention. To the dismay of his fellow Democrats, the West Virginian – who also chairs the Senate Energy and Natural Resources...more

Freeman Law

The King of Pop, Michael Jackson’s, Estate Wins Big at Tax Court

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Two things are virtually certain in life: death and taxes. But, one more should be added to the list where the two converge—an IRS audit. Indeed, this scenario played out all too well for the “King of Pop,” Michael...more

Opportune LLP

Gift & Estate Tax Valuation: 5 Things To Remember

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Here are five things to remember when performing the valuation of shares of a closely held entity for gift and estate tax reporting...more

Cole Schotz

Failure To Plan and Inaction Lead To Increased New Jersey Estate Tax

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The New Jersey Tax Court recently released its opinion in Estate of Ruth Oberg, NJ Tax Court, Docket No 000240 (October 24, 2017), upholding the Division of Taxation’s assessment of additional New Jersey estate tax. The case...more

Proskauer Rose LLP

Wealth Management Update - May 2017

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May Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The May § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs...more

Bowditch & Dewey

New Reporting Regime: Estates Who Have to File Federal Estate Tax Returns Need to be Aware of New Basis Consistency Law

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On July 31, 2015, the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 introduced new tax law that affects executors who are required to file a federal estate tax return and beneficiaries...more

Bowditch & Dewey

A “Thriller” in Tax Court: The Estate of Michael Jackson and IRS Dispute Valuation of Pop Star’s Image

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How much were the late King of Pop’s name and image worth when he died? His estate put the figure at $2,105 but the IRS believes the value is at least $434 million. That’s a huge discrepancy and with penalties and interest...more

Goodwin

IRS Proposes Valuation Discount Regulations: Implications for Family-Controlled Businesses

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IRS issues new proposed rules aimed at eliminating valuation discounts for transfers of interests in family-controlled entities. Clients considering making transfers of interests in such entities should act soon....more

Greenberg Glusker LLP

Transfers of Family-Controlled Business Entities to Family Members Could Get More Expensive

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Transfers of Family-Controlled Business Entities to Family Members Could Get More Expensive - The Internal Revenue Service (IRS) recently released proposed regulations that will dramatically change the valuation of...more

Butler Snow LLP

Owners of Family Controlled Entities Must Act Quickly in Light of New IRS Regulations Attacking Valuation Planning

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Chapter 14 of the Internal Revenue Code consists of four Code Sections (Sections 2701 – 2704) designed to close valuation loopholes. Prior to Congress’s enactment of Chapter 14 in 1990, estate planners had a host of tools...more

Manatt, Phelps & Phillips, LLP

Proposed 2704 Regulations Attack Valuation Discounts

The IRS has expanded the scope of IRC Section 2704 by issuing proposed regulations that seek to limit the availability of valuation discounts for transfers of interests in family-controlled entities. In general, the purpose...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

Davis Wright Tremaine LLP

Proposed Regulations Would Curtail Most Valuation Discounts for Family-Owned Businesses – 2016 Planning Opportunity

Recently proposed Treasury Regulations (“Proposed Regulations”), if enacted as proposed, would curtail valuation discounts that currently reduce the value of certain business interests transferred during life or at death for...more

Cole Schotz

IRS Issues Proposed Regulations Under Code §2704 Impacting Gift and Estate Taxes

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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

Blank Rome LLP

Act Now to Avoid Proposed IRS Rules Which Would Eliminate Valuation Discounts for Intra-Family Transfers of Interests in Family...

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Action Item: Owners of family businesses and investment entities (such as family limited partnerships, limited liability companies (“LLCs”), and corporations) are urged to consider making transfers of interests in those...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

K&L Gates LLP

IRS Plans to Disallow Minority Interest Discounts for Family-Controlled Entities; Action May Be Required Before Year-End

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Gifts and bequests of interests in family-owned companies have traditionally been valued at their fair market values for purposes of calculating the gift or estate tax on the transfer. In valuing these transfers, there is...more

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