WebDec 27, 2024 · Valuation Discounts. When gifts of minority interests are made in an LLC, FLP, or even an operating corporation, valuation discounts are allowed by the Internal Revenue Service in determining the fair market value of the gifted interest. Accordingly, the values of minority ownership interests in these entities are lower than outright ownership ... WebAug 24, 2016 · The recent proposed regulations provide the IRS with more ammunition with which to attack FLP valuation discounts. In particular, the proposed regulations reflect …
Family Limited Partnerships vs. Irrevocable Life …
WebOct 1, 2015 · Bruce A. Johnson, ASA is a partner in the business valuation firm of Munroe, Park & Johnson, Inc. located in San Antonio, Texas. Mr. … WebA valuation discount of about 30% for a gift of the limited partner shares will be assumed in this example. Valuation discounts for lack of marketability and minority ownership interests offer an important … foam osb roof
Now Is Time To Utilize Valuation Discounts for Gift and Estate …
WebMar 10, 2024 · Valuation discounts, often utilized in connection with the transfer of ownership interests in family-owned or closely-held businesses, are a valuable estate … WebIn revenue ruling 93-12, the IRS agreed with earlier court decisions that allowed minority and marketability discounts for transfers of FLP interests. Since publishing that FLP-friendly ruling, however, the IRS has issued several other rulings that deny discounts for transfers of limited partnership interests (PLRs 9719006, 9723009, 9725002 ... Web1. Upon creation of an FLP, there are neither income nor gift tax consequences because the entity created is owned by the same person, or persons, who owned it before the transfer. 2. The primary purpose of an FLP is to transfer assets to younger generations of a family using annual exclusions and valuation discounts. 3. greenwood fish market promo code