WebA family limited partnership (FLP) is simply a limited partnership structure designed to allow senior family members to own a small share of the value of a business. It also allows them to maintain control (often temporarily) while selling, transferring, or giving away much of the value of the business—often at a discount—and to share in ... WebJun 23, 2024 · Nelson and FLP Double Discounting. Recently, the Tax Court issued a memorandum decision in Nelson v. Commissioner, TC Memo 2024-81 (June 10, 2024). …

They’re Still Out There (?) - Tax Law for the Closely Held Business

WebThe discount for a minority/non-controlling interest is determined largely by the degree of control that the limited partners have over the assets in the family limited partnership. … WebAlternatively, he could create a FLP with $1,500,000 and make a gift of a 90% limited partnership interest to his children. He could then file a gift tax return showing a $1,000,000 gift ($1,500,000 times 90% = $1,350,000 less a 26% discount of $351,000 = $999,000 ¾ 26% is a conservative discount). chrysanthemum lowest temperature survivable

Family Limited Partnership - What is One and How it Protects You

WebValuation discounts for lack of marketability and minority ownership interests offer an important incentive to form an FLP. Assume a fair market value appraisal of rental real estate is $16,000,000. What does the FLP … WebAug 24, 2016 · The recent proposed regulations provide the IRS with more ammunition with which to attack FLP valuation discounts. In particular, the proposed regulations reflect the IRS’s position that under Section 2704(b) the ability for any family member to liquidate his or her interest at any time will be presumed if a family controls an FLP, outsiders ... WebThe FLP in Peracchio v. Commissioner, T.C. Memo. 2003-280, contained various types of marketable securities. The taxpayer took a valuation discount of 40%, while the IRS … chrysanthemum lower classifications