Valuation of interests "In Transit": in Family Limited Partnerships

Article Abstract:

Using Family Limited Partnerships (FLP's) to shield members of a family from the federal estate tax is well examined and many taxpayers and their advisors began to dissect the rules under Sections 2701-2704 in an effort to avoid the potentially adverse effects of that legislation. The government has been actively seeking to prevent the owners of FLP's from getting substantial discounts for valuing transferred interests during their lifetime and at death.

Limited partnership, Limited partnerships, Estate tax, Estate taxes, Family-owned business enterprises, Family-owned businesses, Family corporations

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IRS section 2036 assault continues on family limited partnerships

Article Abstract:

With respect to the family limited partnership (FLP), which is used to obtain transfer tax values, the Internal Revenue Service (IRS), has invoked the 2036(a). The purpose is to require full inclusion of the value of all the properties transferred to the FLP. An in-depth analysis of the 2036(a) with respect to the FLPs, is presented.

Tax Law, Public Finance Activities, Taxes, Interpretation and construction, Taxation, Tax policy, United States. Internal Revenue Service, Family limited partnerships

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Valuation of interests 'in transit' in family limited partnerships: Part 3

Article Abstract:

The restrictions in a partnership agreement lapsing at the moment of death are discussed. It is suggested that there is a need for a detailed discussion in cases involving testamentary transfer of a general partnership interest in a family partnership.

Partnerships, Partnership, Partnership distributions

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