Wealth planning with family limited partnerships and limited liability companies / Louis A. Mezzullo, Esq., Withers Bergman LLP, Rancho Santa Fe, California.
2009
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Details
Title
Wealth planning with family limited partnerships and limited liability companies / Louis A. Mezzullo, Esq., Withers Bergman LLP, Rancho Santa Fe, California.
Former Title
Family limited partnerships and limited liability companies <june 24, 2009>
Added Corporate Author
Imprint
Arlington, VA : Tax Management Inc., [2009]-
Description
1 online resource.
Frequency
Updated irregularly
Series
Tax management portfolios ; 722-4th.
Formatted Contents Note
Detailed Analysis. Introduction
Family Limited Partnerships and Limited Liability Companies for Income Tax Purposes
Valuation Issues for Family Limited Partnerships and Limited Liability Companies: In General
Special Valuation Rules Applicable to Family Limited Partnerships and Limited Liability Companies Under Chapter 14 of the Code
Other Transfer Tax Issues Involved with Family Limited Partnerships and LLCs
Choice of Entity
Formation and Liquidation Issues for Family Limited Partnerships and Limited Liability Companies
Drafting Considerations for Family Limited Partnerships and Limited Liability Companies
Business and Other Nontax Reasons for Using Family Limited Partnerships and Limited Liability Companies
Working papers.
Family Limited Partnerships and Limited Liability Companies for Income Tax Purposes
Valuation Issues for Family Limited Partnerships and Limited Liability Companies: In General
Special Valuation Rules Applicable to Family Limited Partnerships and Limited Liability Companies Under Chapter 14 of the Code
Other Transfer Tax Issues Involved with Family Limited Partnerships and LLCs
Choice of Entity
Formation and Liquidation Issues for Family Limited Partnerships and Limited Liability Companies
Drafting Considerations for Family Limited Partnerships and Limited Liability Companies
Business and Other Nontax Reasons for Using Family Limited Partnerships and Limited Liability Companies
Working papers.
Summary
"Tax Management Portfolio, Wealth Planning with Family Limited Partnerships and Limited Liability Companies, No. 722-4th, covers the following topics: Income and transfer tax considerations and nontax considerations relating to the formation, operation and termination of family limited partnerships and limited liability companies (LLCs); The goals of family members in establishing limited partnerships and LLCs; The various techniques available for reducing or eliminating transfer taxes, and the income tax rules pertaining to the recognition of an entity as a partnership for federal income tax purposes; Valuation issues, including the various discounts or premiums that may apply to transfers of interests in limited partnerships and LLCs and the special valuation rules under Chapter 14 as they apply to family limited partnerships and LLCs; The validity of a partnership or LLC formed for the purpose of holding marketable securities and the Internal Revenue Service's challenges to valuation discounts; The availability of the annual exclusion for transfers of interests in family limited partnerships and LLCs and the potential inclusion of transferred interests in the transferor's estate; The issues involved in choosing the appropriate entity for holding family assets, including marketable securities, real estate, and operating businesses with a detailed discussion of the desired characteristics of the family business entity; The issues involved in forming and liquidating the entity, including the potential application of the anti-abuse regulation under the partnership rules, tax-free formation treatment, and classification of the entity for federal tax purposes; The issues involved in forming and liquidating the entity, including the potential application of the anti-abuse regulation under the partnership rules, tax-free formation treatment, and classification of the entity for federal tax purposes; The business and other nontax reasons for a family to use a limited partnership or LLC to hold family investments and operating businesses."
Source of Description
Description based on contents viewed on June 4, 2019; title from description page.
Location
www
Available in Other Form
Print version: Mezzullo, Louis A., 1944- Wealth planning with family limited partnerships and limited liability companies. Arlington, VA : Tax Management Inc., [2019]-
Linked Resources
Alternate Title
BNA Premier package.
Language
English
Record Appears in