Does section 2703 apply to the valuation of family limited partnerships?

Article Abstract:

Most discussion of family limited partnership valuation discounts has focused on IRC section 2704, but there are some indications that section 2703 may be used to attack these estate planning arrangements. If section 2703 is applied, the partnership structure would be disregarded. It could be argued that section 2703 was not intended to apply to family limited partnerships or that an exception under section 2703 is applicable. An unpublished IRS technical advice memorandum suggests that the IRS is interested in employing section 2703 to challenge valuation discounts.

Valuation, Limited partnership, Limited partnerships

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Estate planning with short sales

Article Abstract:

Estee Lauder and her family provide an example of how short sales against-the-box can be used effectively by family owned businesses as an estate planning tool. By holding both short and long positions in stock in Estee Lauder Cos., the family members were able to defer capital gain recognition. Estee Lauder herself may avoid capital gains taxes completely because of the step-up in basis her stock holding will receive at death. This technique is available to more modest family businesses, though Congress is consider legislation that would end shorts-against-the-box.

Methods, Taxation, Short selling

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Taxpayer Relief Act of 1997 offers significant estate planning opportunities

Article Abstract:

The 1997 Taxpayer Relief Act provides numerous estate planning opportunities. The gift and estate tax exclusion increases and the family-owned business exclusion are major changes which could provide large tax breaks with proper planning. The tax-free rollover of gain on a primary residence sale, the ability to defer estate taxes on family businesses, gift tax exclusion indexing, capital gains tax reduction, and other changes are also discussed.

Estate tax, Estate taxes, Gift tax

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