Finalize high net worth planning now! IRS attorney signals looming restrictions on discount techniques.
One of the most effective wealth transfer strategies of the past few decades may be going away this September. For many years, wealthy families have money into Family Limited Partnerships (FLPs) or Family Limited Liability Companies (FLLCs), built in significant restrictions on voting and transfer rights on the equity interests in those entities, and then gifted or sold equity interests to family members at steep discounts, effectively transferring out huge amounts of value at discounted rates. Now with new proposed regulations under IRC §2704(b)(4), the opportunity to do leveraged gifting using valuation discounts could disappear within a few months.
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- Background of IRC §2704(b)(4)
- Implications of proposed regulations under IRC §2704(b)(4)
- Planning considerations for your client