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Insights Business & Tax Blog

2704 Regulations Explained: Proposed Rules Are Set to Further Expand Value Differences between Family-Controlled Entities and Other Companies

September 28, 2016 2704 Regulations

The IRS is focused on reducing valuation discounts associated with transfers of interests in family-controlled businesses, but this focus will result in family members being deemed to receive a different value than non-family members. This also means that an appraiser will be required to establish two different values based on…

What Do Estate Tax Laws in Other Countries Tell Us About the Presidential Candidates’ Proposals?

September 26, 2016 Estate Tax

Under current law, the federal government imposes a 40% estate tax to the extent an individual’s estate exceeds a $5.45 million exemption. Republican presidential nominee Donald Trump advocates eliminating the tax. Democratic presidential nominee Hillary Clinton previously proposed reducing the exemption to $3.5 million and increasing the tax rate to…

Applicable Federal Rates for October 2016

September 22, 2016 Applicable Federal Rates

The Internal Revenue Code prescribes minimum imputed interest rates and time-value-of-money factors applicable to certain loan transactions and estate planning techniques. These rates are tied formulaically to market interest rates. The Internal Revenue Service updates these rates monthly. These are commonly applicable rates in effect for October 2016: Short Term AFR…

2704 Regulations Explained: Proposed Rules Negating Gift and Estate Tax Valuation Discounts May Ensnare Your Vacation Home Too

September 20, 2016 2704 Regulations

As mentioned in several recent posts, the proposed regulations under Code Section 2704 are aimed at reducing valuation discounts associated with transfers of interests in family-controlled businesses. So that the proposed regulations capture certain entities that may be disregarded for federal income tax purposes, such as single-member limited liability companies,…