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Proposed 2704 Regulations: Commercially Reasonable Restriction Exclusion” – What Might it Mean?

August 29th, 2016

Introduction   The Proposed 2704 Regulations prevent taxpayers from considering a range of restrictions that could otherwise reduce the value of an interest in an entity for transfer tax purposes. […]

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Sample Letter Advisers Can Send Clients about 2704 Planning for 2016 Year End

August 27th, 2016

  Dear Client:   Proposed Regulations Just Issued: The Treasury (IRS) just issued Proposed Regulations that could have a dramatic impact on your estate planning by eliminating valuation discounts. For […]

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Using GRATs Prior to the Effective Date of the 2704 Proposed Regulations

August 16th, 2016

Introduction   On August 4, the Treasury Department issued Proposed Regulations that restrict or eliminate valuation discounts for family-owned businesses under IRC Sec. 2704. The Proposed Regulations will be the […]

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Proposed Regulations Will Zap Discounts – Wealthy Taxpayers Should Plan ASAP

August 7th, 2016

Introduction   OK stop holding your breath! The long awaited discount Regs were just issued. 26 CFR Part 25 [REG-163113-02] RIN 1545-BB71. They will be published in the Federal Register […]

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