The IRS recently issued the long-awaited changes to Section 2704(b). The document is summarized as follows,
This document contains proposed regulations concerning the valuation of interests in corporations and partnerships for estate, gift, and generation-skipping transfer (GST) tax purposes. Specifically, these proposed regulations concern the treatment of certain lapsing rights and restrictions on liquidation in determining the value of the transferred interests. These proposed regulations affect certain transferors of interests in corporations and partnerships and are necessary to prevent the undervaluation of such transferred interests.
Click here to view the full document: IRS Reg 163113-02
Posted by Allison Trupp, Associate Editor, Wealth Strategies Journal