Treasury Department’s Tax Lawyer Reports: “It’s Not Over Til It’s Over…”

Dear Clients, Colleagues, and Friends, On August 4, 2016, the IRS issued proposed regulations under IRC Sec. 2704 designed to eliminate a commonly used and effective wealth transfer strategy to produce “discounts” in value for lack of marketability and lack of control when making transfers of closely held entity interests via gift or by one’s will or living trust. These discounts can range from 25% to 50% or more depending on the nature of the entity, the capital structure of […]

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