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MPI Comments on Proposed IRS Regulations

After more than a year of speculation and rumors, on August 4, the Internal Revenue Service (“IRS”) issued proposed regulations under Internal Revenue Code §2704 (the “Proposed Regs”). Clearly, the goal of the Proposed Regs is to limit (or eliminate outright) the application of discounts for lack of control and lack of marketability when valuing interests in family controlled entities for gift, estate and generation-skipping tax purposes.

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Section 2704 Changes Coming?

The Trusts & Estates community has been abuzz about potential new interpretations regarding Internal Revenue Code Section 2704 since Treasury attorney Catherine Hughes spoke at the ABA RPTE Conference in Washington, D.C. in late April. The proposed rules are known as the “valuation discount rules” or “disregarded restrictions” and are thought to be a new tool in the government’s stance against discounts taken on interests in family owned companies and partnerships for gift and estate tax purposes.

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Trusts & Estates Valuation Update: The Latest on Cases, Audits and the Environment

We are in a period where many estate planners are increasing their focus on matters other than the federal exemptions. Some practitioners are contemplating the balance between minimizing estate and gift tax with minimizing income tax...

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