Webcharacteristics may make FLPs eligible for valuation discounts. When applied, valuation discounts reduce the value of the FLP’s underlying assets for gift tax purposes when its shares are given to family members during the FLP creator’s life and for estate tax purposes following the creator’s death. Background on SOI’s Estate Tax Study WebDarrin and his wife, Kathi, want to establish a family limited partnership (FLP) and transfer their business to the FLP. The value of the business interest is $4,000,000. They want to make use of the annual exclusion and have been advised that a 25% discount is appropriate for gifting a minority interest of limited partnership shares.

Family Limited Partnerships & Discounting

http://texasprobate.net/faqs/flpfaq.htm WebLLC and FLP interests are inherently subject to: Lack of Marketability. An interest in an entity that is not registered and readily tradable, e.g. stock in a publicly traded company, … city center praha

Compendium of Federal Estate Tax and Personal Wealth Studies

Webinfluence the discounts that may apply in estimating the fair market value of a noncontrolling, nonmar-ketable FLP and FLLC ownership interest for estate and gift tax … WebThe pre-990 studies showed an average discount of 34%, while the 1990–1997 studies showed an average discount of 22%. The IRS expert proposed that the 12% differential reflected the effect of the opening of a limited resale market and thus the portion of a marketability discount related to lack of a liquid market. WebAug 24, 2016 · This presumption prevents valuation discounts from being applied, at least when the FLP primarily owns marketable securities. The proposed regulations further … dick winters documentary