Discounting and Valuing Family Limited Partnership Interests, and Buy-sell Agreements PDF Download
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Author: Michael A. Yuhas
Publisher:
ISBN:
Category : Estate planning
Languages : en
Pages : 360
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Book Description
Author: Michael A. Yuhas
Publisher:
ISBN:
Category : Estate planning
Languages : en
Pages : 360
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Book Description
Author: David T. Lewis
Publisher: American Bar Association
ISBN: 9781590318171
Category : Business & Economics
Languages : en
Pages : 350
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Book Description
Forming and funding a family limited partnership or limited liability company is both increasingly common and complicated. This current, comprehensive reference provides in-depth analysis of all facets of using these planning vehicles. It begins with detailed guidance on the basic principles of drafting, forming, funding, and valuing an FLP or LLC, but also covers advanced income tax concerns. Added tools include examples and extensive sample forms on CD-ROM.
Author: Brad Galbraith
Publisher:
ISBN: 9780314279330
Category : Family partnership
Languages : en
Pages : 0
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Book Description
Written by an attorney whose practice focuses on the estate and tax planning needs of high net worth families, Family Limited Partnership Agreements Line by Line is a comprehensive examination of the contract provisions that make family limited partnerships such a powerful tax planning and asset protection tool. This publication includes in-depth explanations of the reasoning behind the various provisions in the agreementthose that are crucial to the general partner, as well as those that simply make operations more predictable and efficient for all partners. The book covers such key topics as entity creation, ownership interests, capital contributions and capital accounts, allocations and distributions, entity management, transfers of general partner and limited partner interests, and dispute resolution. Family Limited Partnership Agreements Line by Line is a valuable resource for anyone who works with business owners and high net worth families, as well as those individuals who are interested in capitalizing on family limited partnership planning opportunities. This book contains a CD-Rom that features the PDF and Word versions of the final text of the book, which enables readers to manipulate the contract.
Author: Lewis D. Solomon
Publisher:
ISBN:
Category : Business & Economics
Languages : en
Pages : 440
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Book Description
This handbook analyzes all methods of valuation for all types of closely held businesses in all transactions. The authors lead you through the valuation process, step by step, beginning with the basics and progressing to special considerations. With this comprehensive volume, you will be prepared For The valuation issues that arise when a closely held business is part of Structuring a buy-sell agreement Arranging equitable distribution in a marital dissolution A merger or acquisition Federal estate and gift tax planning Litigation by dissenting shareholders seeking an appraisal remedy Bankrupstcy or reorganization Dissolution or liquidation Whether your work involves traditional business organizations such as corporations, proprietorships, and partnerships or new entity forms such as limited liability companies and family limited partnerships, you'll find this thorough resource offers easy access to specific information. The authors reinforce their explanations with practice and planning pointers, illustrative examples, 'cautions' to alert you to potential problems, checklists, and convenient tables of cases and citations. Save precious time by keeping Valuations of Closely Held Business: Legal and Tax Aspects close at hand.
Author: David R. Nave
Publisher:
ISBN:
Category :
Languages : en
Pages : 0
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Book Description
Highlights the unsuccessful efforts by the IRS in challenging valuation discounts associated with gifts of family limited partnership interests. Advises that the IRS's new approach involves the application of Code Section 2036(a) to include the underlying partnership assets in the transferor's estate without any discounts. Summarizes the estate tax inclusion in Code Sec. 2036(a), outlining the three requirements for includability. Focuses on the element of control maintained by the transferor. Reviews a case in which the IRS argued that underlying assets were includible under Code Sec. 2036(a). Analyzes the original Tax Court opinion and second Tax Court opinion after remand from the Fifth Circuit. Addresses the retained enjoyment and retained control aspects of Code Sec. 2036(a), and considers the relevance of the Byrum case relating to transferred stock. Discusses the exception for a bona fide sale for adequate and full consideration. Reviews a district court case which also applied Code Sec. 2036(a) to a family limited partnership transaction. Notes that the taxpayer argued for application of the bona fide sale exception. Offers extensive planning suggestions for avoiding a challenge under Code Sec. 2036(a) to transfers of family limited partnership interests.
Author: Reed W. Easton
Publisher:
ISBN:
Category :
Languages : en
Pages : 0
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Book Description
Family Limited Partnerships ("FLPs") and Limited Liability Companies ("LLCs") are commonly used in estate planning to transfer real estate, marketable securities or other assets to family members with valuation discounting used in determining the gift or estate tax consequences. Parents retain control over their assets under the terms of the FLP or LLC agreement while reducing the potential estate tax applicable thereto through the use of valuation discounts attributable to the FLP or LLC interests. Recently, the IRS has been aggressively using Section 2036 in estate tax cases to attack the FLP and LLC strategy for valuation adjustment. A new decision overshadows all the former decisions in its expansive interpretation of Section 2036 (a) (2). This article will look at that decision Estate of A. Strangi TC Memo 2003-145 (May 20, 2003) (i.e. "Strangi II") and identify possible practitioner responses. These possible responses will address current estate planning as well as what the practitioner might do with existing FLPs/LLCs and in the event of a gift or estate tax return examination. Lee Iacocca has been quoted as saying - "We are continually faced by great opportunities brilliantly disguised as insoluable problems." This article is directed to identifying those available opportunities. The FLP/LLC Technique has been around for more than eight years and now the retention of control may avoid any possibility of a valuation discount. Should bad facts be allowed to make bad law? What is the effect of Strangi II on future estate planning? Those parents who already have existing FLPs/LLCs have available alternatives to choose from. What does the new Strangi II decision mean prospectively to the practitioner and his or her clients?
Author:
Publisher:
ISBN:
Category : Estate planning
Languages : en
Pages : 288
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Book Description
Author: James R. Hitchner
Publisher: John Wiley & Sons
ISBN: 1119312353
Category : Business & Economics
Languages : en
Pages : 472
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Book Description
Practical valuation exercises with real-world application and expert insight Financial Valuation Workbook cuts the learning curve in half, with practical training for use with any valuation textbook. Packed with tools, resources, and over 300 exercises, this book helps novices get a handle on the complex valuation process, while helping more experienced practitioners organize their engagements. Checklists, flowcharts, reports, information requests, and other resources help streamline the workflow and ensure thorough review, while in-depth coverage places the complexities of the field front-and-center. This new fourth edition features a brand new expanded case study for real-world insight, accompanied by exercises with explanations that deepen the learning process. Expert tips are highlighted throughout to provide additional insight in specific situations, and exercises from basic to advanced map to established training processes. Valuation is as an art, as well as a science, and simply reading a textbook only goes halfway toward true learning—applying what you learn is critical. This book provides hands-on practice alongside useful tools and valuable insight to help solidify your understanding of the many facets of this complex field. Delve into the intricacies of valuation with a new expanded case study and expert tips Follow checklists and flowcharts for each phase of the valuation process Use reports, information requests, and other tools that help organize your workflow Test your understanding with over 300 exercises organized by major area Organized into standard, recognized, and easily identified sections that lend themselves to quick refreshers as well as start-to-finish study, this book is a truly useful resource for beginner and veteran alike. Whether you're learning valuation for the first time or simply need guidance on an unfamiliar situation, Financial Valuation Workbook provides a key resource for any business valuation professional.
Author: Louis A. Mezzullo
Publisher: Real Prop, Trust, Estate ABA
ISBN:
Category : Business & Economics
Languages : en
Pages : 158
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Book Description
Designed for the estate planner assisting the owners of a closely held business in structuring arrangements to deal with the withdrawal of an owner.
Author: Louis A. Mezzullo
Publisher: Section of Real Property Probate & Trust Law
ISBN:
Category : Business & Economics
Languages : en
Pages : 220
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Book Description
