Family Partnerships and LLCs: Valuation Discounts, IRS Challenges, and IRC Section 2036
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This course will provide tax advisers who work with high net worth individuals a comprehensive look at family limited partnerships and family limited liability companies. The speakers will discuss the current landscape involving valuation discounts for estate and gift tax purposes and detail the specific issues surrounding recent cases. The webinar will also address the interplay between estate planners and income tax advisers, in particular with respect to planning to obtain a step-up in basis upon death.
Outline
- Background: family partnerships and family limited liability companies
- Valuation discounts: it’s not just lack of control and lack of marketability
- Recent IRS challenges: what are the cases you need to know about
- Proper structuring and execution: how to avoid the pitfalls of Section 2036
- Interplay with income tax, estate tax, and basis step-up
Benefits
The panel will discuss these and other important issues:
- How does IRC Section 2036 impact FLPs, FLLCs, and other family-controlled entities?
- Which high net worth individuals are the best candidates for these entities?
- What lessons have been learned from recent IRS challenges to family-controlled entities?
Faculty
Renee Gabbard
Partner
Bryan Cave Leighton Paisner
Ms. Gabbard’s practice focuses on privately held businesses, high net worth clients, and charitable... | Read More
Ms. Gabbard’s practice focuses on privately held businesses, high net worth clients, and charitable organizations. Her areas of practice include all aspects of income, capital gains, gift and estate tax planning, charitable planning, advanced wealth and business succession planning, capital gains tax deferral techniques, acquisition, sale and liquidity planning, private corporate structuring, asset freeze techniques, family office planning, insurance planning, trust tax planning, and trust administration.
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Carsten Hoffmann
Managing Director, Trust & Estate Valuation Practice Co-Leader
Stout Risius Ross
Mr. Hoffmann has more than two decades of valuation expertise and is a recognized expert on a broad range of complex... | Read More
Mr. Hoffmann has more than two decades of valuation expertise and is a recognized expert on a broad range of complex valuation issues related to estate and gift tax, income tax, litigation support and dispute resolution – including the quantification of discounts for lack of control and lack of marketability pertaining to business and real property interests. As a leader in the valuation industry, Mr. Hoffmann has testified in U.S. Tax Court as a valuation expert, has authored a number of articles on a wide range of valuation topics, and regularly presents on valuation issues nationally. He co-leads Stout’s Trust & Estate Valuation practice and is head of Stout’s Irvine, California office.
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