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In the August, 2011 issue of BVUpdate™ John Porter noted "recent court decisions have dealt a blow to the effectiveness of family limited partnerships (FLPs) for transfer tax purposes, particularly when the partnership formation and funding fail to respect state law requirements. In these cases, the IRS has successfully attacked the FLPs—often nullifying any valuation discounts—by focusing on their lack of economic substance/business purpose, or characterizing the asset transfers as indirect gifts/gifts-on-formation."
In "Family Limited Partnerships: The Current Landscape," the first installment of BVR's Online Symposium on Estate & Gift Tax Porter, an expert attorney and CPA, joins us to discuss the changing landscape of FLPs. From how recent IRS tactics and court cases have affected the regulatory treatment of FLPs to how appraisers should approach these valuation assignments, Porter will address what everyone must know when operating in this challenging and changing space.
Program Agenda
Overview
Basic valuation principles
Dealing with the IRS's arguments regarding FLPs
IRC § 2073 argument
The indirect gift/gift on formation argument
Disregarded entities/step transaction
Annual exclusion gifts
IRC § 2036(a)
Significant § 2036 cases
Appeals coordinated issues settlement guidelines
Formula transfers
Value adjustment clauses
Value definition clauses
Recent decisions favor the use of formula clauses
Gift tax reporting
Income tax issues
Graegin notes
Various valuation adjustments
Privileges in the estate planning context
Working with attorneys, working with appraisers
Where are we now and where are we headed?
Learning Objectives
Learn how IRS regulations - and the courts' interpretations of those regulations - have and will impact FLP valuations
Understand how formula clauses and other strategic language fits with FLP valuations, assessments, and IRS reviews
Learn how Graegin Notes fit in estate & gift valuations and regulations
Clarify best practices with regard to the appraiser's role in FLP valuations, litigations, depositions, and other actions
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