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Darren Wallace and Ed Krzanowski were quoted in an article, "Valuation discounts: what could the IRS’ new proposal mean for families?" in Private Asset Management Magazine. In the article, Wallace and Krzanowski discuss the recently issued proposed regulations under Internal Revenue Code Section 2704 that, if finalized, would curtail or eliminate valuation discounts for gift and estate tax purposes. These regulations would affect the gift and estate tax value of family-owned business entities, including both active businesses and family investment vehicles such as family limited partnerships (FLPs) and limited liability companies (LLCs). For individuals who have an interest in a family-owned business entity and an estate that could be subject to federal or state estate tax (and thus affected by no longer being able to value those interests based on fractional-interest or other discounts), these regulations could have a major impact on them.
