Below-market loans offer tax arbitrage potential

Article Abstract:

The author discusses the law under IRC section 7872 which was enacted to address tax planning abuses concerning interest rates and below-market loans. Statutory language, legislative history, and limited IRS guidance are examined.

Interest, Interest (Finance), Loans

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Hold on to special-use valuation estate tax saviings

Article Abstract:

The author explains the substantive law applicable and the complex administrative issues which arise when the IRC section 2032A special-use valuation for family farms and businesses is elected as a means to reduce estate tax.

Personal Tax Planning, Laws, regulations and rules, Personal finance, Estate tax, Estate taxes, Family-owned business enterprises, Family-owned businesses, Tax elections, Family farms

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Give more and pay less tax by claiming valuation discounts

Article Abstract:

The author discusses the use of valuation discounts when valuing closely held businesses as a means to reduce transfer taxes. The discussion includes several judicial and administrative authorities.

Estate Planning, Securities, Transfer taxes, Close corporations, Closely held corporations, Discount (Finance)

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