FLP Planning After the Most Recent Tax Acts: What Should Planners REALLY Be Focusing On – Louis S. Harrison, Esq.
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1. What pivotal family partnership case established that because the restrictions in the partnership agreements are not “applicable restrictions” to be disregarded under § 2704(b), the special valuation rule in I.R.C. § 2704(b) does not apply to the valuations of the partnership interests transferred.
2. For an LLC to work for discounting purposes…
3. An LLC may be a better choice than a Family Limited Partnership as a basis for avoiding IRS scrutiny…
4. Which Code Section provides that if built-in gain property contributed by one partner is distributed from the partnership to another partner within seven years of contribution, that built-in gain is recognized to the contributing partner as if the property had been sold by the partnership.
5. The establishment of family limited partnerships poses opportunities, as well as challenges, to the estate planner. Some of the most important income tax issues that should be considered by the estate planning practitioner in structuring the partnership transaction include…