Dinner Meeting: The Elimination of (Most) Valuation Discounts
The Elimination of (Most) Valuation Discounts
Presenter Nick Hulwi
The Internal Revenue Service has issued proposed regulations with the purpose of preventing the undervaluation of intra-family transfers of interests in corporations and partnerships for estate, gift and generation-skipping transfer tax purposes. Specifically, the proposed regulations address the treatment of certain lapsing rights and restrictions on liquidation in determining the value of these interests.
These regulations clarify that section 2704 applies to corporations, partnerships, LLCs, and other entities/arrangements that are business entities, regardless of whether the entity/arrangement is domestic or foreign, and regardless of how the entity/arrangement is classified, or is disregarded as an entity separate from its owner, for other federal tax purposes.
Learning Objectives
By the end of the session, attendees will:
- Understand the basics of section 2704
- Identify the key differences between the current and proposed regulations
- Appreciate the impact of the proposed regulations on intra-family transfers
Networking and Registration: 4:30-5:00 pm
Presentation: 5:00-6:00 pm
Dinner: 6:00-7:00 pm
Crowne Plaza Northstar
618 Second Avenue South
Minneapolis, Minnesota 55402
612-338-2288
