Proposed Regulations for the Valuation of Interests
The IRS recently released a notice of proposed rulemaking and notice of public hearing entitled, Estate, Gift, and Generation-Skipping Transfer Taxes; Restrictions on Liquidation of an Interest. Provided below is a summary on the proposed regulations:
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.
Special thanks to Robert Wolf (Attorney, Tener, Van Kirk, Wolf & Moore, P.C.) for bringing this to my attention.