Steve Akers, Associate Fiduciary Counsel, Bessemer Trust, provides the following summary of Pierre v. Commissiner, 133 T.C. No. 2 (Aug. 24, 2009).
Transfers of Interests in Single-Member LLC Treated as Transfers of Interests in the Entity Rather Than as Transfers of Proportionate Shares of the Underlying Assets (Without a Discount)Posted by Lewis J. Saret, General Editor, Wealth Strategies Journal.
Gifts and sales of interests in a single-member LLC to two trusts (12 days after the LLC was created) are treated for federal gift tax purposes as transfers of interests in the entity (with the possibility of discounts) rather than as transfers of proportionate shares of the underlying assets owned by the LLC, even though the single-member LLC is treated as a disregarded entity pursuant to the check-the-box regulations. The regulations provide that "whether an organization is an entity separate from its owners for federal tax purposes is a matter of federal tax law and does not depend on whether the organization is recognized as an entity under local law." The issue is whether the reference to "for federal tax purposes" includes valuing transfers for federal gift tax purposes. The Tax Court's conclusion, treating the transfers as transfers of interests in the LLC (subject to discounts for lack of control and lack of marketability) rather than as transfers of a proportionate share of LLC assets, came from a rather divided Tax Court (with 10 judges joining the majority and 6 judges dissenting). A separate opinion will address "(1) Whether the step transaction doctrine applies to collapse the separate transfers to the trusts and (2) the appropriate valuation discount, if any."
Please click here for a more detailed analysis of the Pierre case.
The respondent found issue with the actions of the petitioner, asserting that the petitioner was liable under CRAT anti-abuse regulation and additionally owed taxes from capital gain income generated from the partnership Latin escorts London best penis enlargement pills
However, the court decided that the deficiency notice was invalid as it was issued before the conclusion of partnership-level proceedings
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The respondent found issue with the actions of the petitioner, asserting that the petitioner was liable under CRAT anti-abuse regulation and additionally owed taxes from capital gain income generated from the partnership. However, the court decided that the deficiency notice was invalid as it was issued before the conclusion of partnership-level proceedings Kensington Escorts Penis Pump
However, the court decided that the deficiency notice was invalid as it was issued before the conclusion of partnership-level proceedings London Escort Agency Lifestyle
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[T]ransfers to the trusts should be valued for Federal gift tax purposes as transfers of interests in Pierre LLC and not as transfers of a proportionate share of the underlying assets of Pierre LLC.
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The regulations provide that whether an organization is an entity separate from its owners for federal tax purposes is a matter of federal tax law and does not depend on whether the organization is recognized as an entity under local law penis enlargement and male enhancement herbs.
The regulations provide that whether an organization is an entity separate from its owners for federal tax purposes is a matter of federal tax law and does not depend on whether the organization is recognized as an entity under local law penis enlargement and male enhancement herbs.
The regulations provide that whether an organization is an entity separate from its owners for federal tax purposes is a matter of federal tax law and does not depend on whether the organization is recognized as an entity under local law penis enlargement and male enhancement herbs.
The regulations provide that whether an organization is an entity separate from its owners for federal tax purposes is a matter of federal tax law and does not depend on whether the organization is recognized as an entity under local law penis enlargement and male enhancement herbs.
The regulations provide that whether an organization is an entity separate from its owners for federal tax purposes is a matter of federal tax law and does not depend on whether the organization is recognized as an entity under local law penis enlargement and male enhancement herbs.
The regulations provide that whether an organization is an entity separate from its owners for federal tax purposes is a matter of federal tax law and does not depend on whether the organization is recognized as an entity under local law penis enlargement and male enhancement herbs.
The regulations provide that whether an organization is an entity separate from its owners for federal tax purposes is a matter of federal tax law and does not depend on whether the organization is recognized as an entity under local law penis enlargement and male enhancement herbs.