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Special-use valuation covers business, as well as farm, realty

Article Abstract:

The special use valuation in IRC 2032A can be used for either farm realty or closely held business realty. Using this provision can result in significant estate tax savings. Estate planners may want to recommend increasing the special use property's value so that their clients can meet the percentage tests. In order to avoid triggering the recapture tax, there there should be an expectation that the heirs will continue the business. The recapture tax would also be triggered by sale of a business in poor condition after the decedent's death to someone outside the family.

Author: Rediess-Hoosein, Brenda J., Apfel, Kenneth S.
Publisher: Warren, Gorham & Lamont, Inc.
Publication Name: Estate Planning
Subject: Law
ISSN: 0094-1794
Year: 1993
Laws, regulations and rules, Special use valuation (Taxation)

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Split-dollar life insurance: updated planning techniques

Article Abstract:

There are many new uses that can be made of split-dollar financed life insurance. Life insurance trusts and S corporations may use split-dollars, and reverse split-dollar financing is also available. The tax breaks for annual gifts and the $1 million generation skipping transfer can both be leveraged with split-dollars. Cross-purchase buy-sell agreements can be financed by split-dollars, and lifetime cash value policies such as second-to-die may be used for split-dollars.

Author: Gislason, Scott H.
Publisher: Warren, Gorham & Lamont, Inc.
Publication Name: Estate Planning
Subject: Law
ISSN: 0094-1794
Year: 1993
Analysis, Split-dollar life insurance, Split dollar life insurance

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Subjects list: Methods, Estate planning
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