A value reduction strategy for family owned real estate
Article Abstract:
Families with substantial real estate holdings that anticipate being subject to estate taxes should consider the use of value reduction strategies to reduce the erosion of wealth that can occur by holding property until death. The preferred vehicle for holding the property is the limited liability company because liability for environmental remediation is limited and the property is not freely transferable. The lack of transferability, paired with discounts for fractionalizing the property interests, will result in substantial valuation reductions.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1996
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Subchapter S and the estate planner
Article Abstract:
Revisions to S corporation rules enacted under the Small Business Job Protection Act of 1996 will provide additional estate and family business succession planning opportunities. The number and types of permissible shareholders have been expanded. Trusts and certain corporations can now hold S stock. Estate valuation discounts can be created by the use of voting and non-voting stock, and S corporation stock can be used to effect estate freezes.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1997
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Escaping income and transfer taxes: a tax plan too good to be true?
Article Abstract:
Wealthy persons may find value in the use of a form of combined trust which may result in no US income taxation of accumulated income and the possible escape of estate, gift, or generation-skipping transfer taxes. This may be accomplished by a trust form consisting of two complex offshore trusts and a domestic dynasty trust.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1999
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