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Special Teleconference: Valuation Vendetta: 2704 Regs Seek to Dump Discounts

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Description

Summary
On Thursday, August 4, the IRS published proposed new regulations under Section 2704 of the Internal Revenue Code. These proposed regulations, if finalized in their current form, will have a monumental impact on tax planning for many estates potentially subject to estate tax. In particular, valuation discounts for certain intra-family transfers of equity in corporations and partnerships, for many years widely available, may be severely limited going forward. In this teleconference, Clary Redd and Turney Berry will explain what Section 2704 was intended to address when it was enacted, how it has worked up to now and what these new proposed regulations seek to accomplish. Among other things, Clary and Turney will discuss:

  • Big change in definition of "applicable restriction"
  • New category of "disregarded restrictions"
  • New three-year rule
  • Effect of nominal non-family held interests
  • Operating businesses vs. entities holding passive investments
  • Possible court challenges
  • Effective date
Cancellation Policy
If you wish to cancel your teleconference registration prior to the time the program Materials (Intellectual Property)/Pin are sent out by BSB, then you will be allowed a full refund of your registration fee. If you wish to cancel your teleconference registration AFTER the program Materials (Intellectual Property)/Pin are sent out by BSB, then you will be charged a $100 cancellation/materials fee.

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State CE Exceptions:
Attorneys must apply for CLE approval
30 days before event date or earlier.
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Kansas Attorneys must apply for CLE approval 30 days before event date or earlier.

Contributors

  • Charles A. Redd

    Charles A. ("Clary") Redd is a partner in the St. Louis office of Stinson LLP. Clary concentrates his practice in estate planning, estate and trust administration and estate and trust-related litigation. He is an elected member of The American Law Institute, a Fellow of The American College of Trust and Estate Counsel and an Adjunct Professor of Law at Northwestern University School of Law. He also serves as Co-Chair of the Editorial Advisory Board of, and writes a regular column in, Trusts & Estates magazine. He is listed in The Best Lawyers in America and is nationally ranked by Chambers USA in its “Wealth Management” category.

  • Turney P. Berry

    Turney P. Berry is a Member of the Executive Committee and the Chair of Wyatt, Tarrant & Combs’ 22 lawyer Trusts, Estates & Personal Planning Service Team. Turney is a Fellow of the American College of Trust and Estate Counsel and the American College of Tax Counsel, a Uniform Law Commissioner and member of the Joint Editorial Board for Uniform Trust and Estate Acts, a Trustee of the Southern Federal Tax Institute and a member of the Advisory Council of the Heckerling Institute on Estate Planning as well as a Member of the Advisory Board of Trusts and Estates Monthly and a Vice-Chair of the Charitable Planning section for the ABA Section of Real Property, Trust and Estate Law. He is listed in Woodward/White’s The Best Lawyers in America®.

August 30, 2016
Tue 1:00 PM EDT

Duration 2H 0M

This live web event has ended.

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