FLP | Perspectives

Entries Tagged ‘FLP’:

Elimination of FLP Discounts?

filed in family limited partnerships on Feb.02, 2010

There have been numerous rumors surrounding whether Congress intends to eliminate discounts on transfers of family limited partnership interests and intra-family transfers of business interests. You may recall that the Pomeroy Bill proposed to eliminate these discounts. While this particular bill has not moved forward (and I understand is dead), it could come up in [...]

Tags: DLOC, DLOM, exemption, family limited partnerships, federal estate tax, FLP, FLP Discounts, gift and estate tax, HR 4154, intra-family transfers, Pomeroy Bill, rate reductions, tax bill, tax rates, valuation and litigation in Casa Grande, valuation and litigation in Phoenix, valuation and litigation in Scottsdale, valuation and litigation in Tempe

Step Transaction Doctrine

filed in Valuation on Oct.06, 2009

A recent case in the federal district court highlights the need to have some time elapse between the date of formation and funding of an FLP or FLLC and the date of gifting of interests in the FLP/FLLC. In Heckerman v U.S., the taxpayers (David and Susan Heckerman) took the following steps in gifting of [...]

Tags: asset transfers, date of funding, date of gift, federal tax liability, FLLC, FLP, funding, gift tax, gifting, gifting of interests, indirect gift, interdependence test, lack of marketability, mutual funds, Quitclaim Deed, step transaction doctrine, step-transactions, trusts, valuation and litigation in Casa Grande, valuation and litigation in Scottsdale, valuation and litigation in Tempe

Perspectives

Demystifying Valuation, Economic Damages and Forensic Accounting

Entries Tagged ‘FLP’:

Elimination of FLP Discounts?

Step Transaction Doctrine

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