Estates, Gifts, And Trusts (EGT)

Transfers of Interests Family Entities Under Chapter 14: Sections 2701, 2703 and 2704 (Portfolio 835)

  • This Portfolio analyzes the historical and current federal estate and gift tax treatment of “estate freezing” transactions.

Description

Tax Management Portfolio, Transfers of Interests in Family Entities Under Chapter 14: Sections 2701, 2703 and 2704, No. 835, analyzes the historical and current federal estate and gift tax treatment of “estate freezing” transactions. After reviewing the development of estate freezing techniques, the portfolio briefly discusses former §2036(c), which was designed to bring back into a transferor’s estate property he or she had actually or constructively transferred in certain “freeze” transactions. The portfolio then analyzes in detail §§2701, 2703, and 2704, effective generally for transactions taking place after October 8, 1990.

In the context of discussing the valuation rules imposed by §§2701, 2703, and 2704 and the associated regulations, the portfolio describes relevant special issues in estate and business planning. These include retained interests, transfers of equity interests in corporations where market quotations are not available to value the retained interests, the impact of buy-sell agreements, and the treatment of “lapsing” rights and restrictions in corporations and partnerships.

For a detailed discussion of §2702, see 836 T.M., Partial Interests — GRATs, GRUTs, QPRTs (Section 2702).

This portfolio may be cited as Mezzullo, 835 T.M., Transfers of Interests in Family Entities Under Chapter 14: Sections 2701, 2703 and 2704.

Table of Contents

I. Introduction and History
II. Section 2701 – Transfers of Interests in Corporations and Partnerships
III. Section 2703 – Buy-Sell Agreements and Options
IV. Section 2704(a) – Lapsing Voting and Liquidation Rights
V. Section 2704(b) – Liquidation Restrictions
VI. Statute of Limitations, Study, and Effective Dates

Louis Mezzullo
Consulting Partner
Withersworldwide
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