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Has Your Family Partnership Become a Family Liability?

Non-controlling family partnership interests with limited marketability have long been discounted for federal gift and estate tax valuation purposes, reducing their deemed fair market value and the...

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IRS Rattles Its Saber to Restrict Family Partnership Planning. What Should...

If you are, or someone that you know is, considering transferring an ownership interest in a family controlled entity the best time may be now.  Speculation abounds over the impact that potential new...

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IRS Targets Valuation Discounts on Family Controlled Entities

The Treasury has followed through on its promise to issue proposed regulations that are intended to significantly reduce the lack of control and lack of marketability discounts applied by appraisers...

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2704 Regulations Explained: Why is the IRS Targeting Valuation Discounts on...

The simple answer is that the IRS believes that valuation discounts taken on family controlled entities are falsely high, which results in lower transfer tax revenue to the Treasury.  With the...

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2704 Regulations Explained: Winners and Losers of Proposed §2704 Regulations,...

The recently issued proposed regulations under Code Section 2704 are specifically targeted at substantially reducing valuation discounts associated with family-controlled businesses.  The clear losers...

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2704 Regulations Explained: Proposed Rules Negating Gift and Estate Tax...

As mentioned in several recent posts, the proposed regulations under Code Section 2704 are aimed at reducing valuation discounts associated with transfers of interests in family-controlled businesses....

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2704 Regulations Explained: Proposed Rules Are Set to Further Expand Value...

The IRS is focused on reducing valuation discounts associated with transfers of interests in family-controlled businesses, but this focus will result in family members being deemed to receive a...

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IRS Sees the Light and Withdraws §2704 Proposed Regulations

The Treasury Department’s issuance of proposed regulations under Code Section 2704 were met with significant criticism and confusion. The §2704 proposed regulations were intended to provide the IRS...

View Article


Has Your Family Partnership Become a Family Liability?

Non-controlling family partnership interests with limited marketability have long been discounted for federal gift and estate tax valuation purposes, reducing their deemed fair market value and the...

View Article


IRS Rattles Its Saber to Restrict Family Partnership Planning. What Should...

If you are, or someone that you know is, considering transferring an ownership interest in a family controlled entity the best time may be now.  Speculation abounds over the impact that potential new...

View Article

IRS Targets Valuation Discounts on Family Controlled Entities

The Treasury has followed through on its promise to issue proposed regulations that are intended to significantly reduce the lack of control and lack of marketability discounts applied by appraisers...

View Article

2704 Regulations Explained: Why is the IRS Targeting Valuation Discounts on...

The simple answer is that the IRS believes that valuation discounts taken on family controlled entities are falsely high, which results in lower transfer tax revenue to the Treasury.  With the...

View Article

2704 Regulations Explained: Winners and Losers of Proposed §2704 Regulations,...

The recently issued proposed regulations under Code Section 2704 are specifically targeted at substantially reducing valuation discounts associated with family-controlled businesses.  The clear losers...

View Article


2704 Regulations Explained: Proposed Rules Negating Gift and Estate Tax...

As mentioned in several recent posts, the proposed regulations under Code Section 2704 are aimed at reducing valuation discounts associated with transfers of interests in family-controlled businesses....

View Article

2704 Regulations Explained: Proposed Rules Are Set to Further Expand Value...

The IRS is focused on reducing valuation discounts associated with transfers of interests in family-controlled businesses, but this focus will result in family members being deemed to receive a...

View Article


IRS Sees the Light and Withdraws §2704 Proposed Regulations

The Treasury Department’s issuance of proposed regulations under Code Section 2704 were met with significant criticism and confusion. The §2704 proposed regulations were intended to provide the IRS...

View Article
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