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Transfer of assets & business interests: Proposed Treasury Regulations Under IRC Section 2704 Would All But Eliminate Valuation Discounts

by Paul McGloin Client Considering Planning Transfers May Wish to Implement Them Prior to December 1st It is rare that a proposed Treasury Regulation gets much attention from estate planning practitioners, especially ones issued during the vacation month of August. However, on August 4th the IRS issued proposed Treasury Regulations under a little-used section of the Internal Revenue Code that may represent one of the biggest changes in estate planning law in the past thirty years. Planners around the country have spent much of the past month huddled in discussion groups and on conference calls to try to understand what these far-reaching changes mean for their clients. For decades, when making transfers of interests in family-owned businesses, planners have relied on valuation discounts to reduce the

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