Blogs

Tax Law

Tax Court Finds Gifts of Limited Partnership Interests Don’t Qualify for Annual Gift Tax Exclusion

The Tax Court ruled that gifts of limited partnership interests may not qualify for the annual gift tax exclusion if the recipient does not have an immediate right to use, possess, enjoy, or transfer the gifted interest. In this Bean, Kinney & Korman article published in the BKK Wills, Trusts and Estates Newsletter, Jonathan C. Kinney explains that the court followed its earlier decision in Hackl and found that the Price family’s limited partnership interests were “future interests” rather…

March 1, 2010

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Tax Law

Tax Law: FIN 48: Will It Be The Feared Road Map for IRS?

FIN 48 expanded the disclosure obligations tied to uncertain tax positions and created concern that businesses would effectively be giving the IRS a roadmap to challenge their tax returns. In this Bean, Kinney & Korman article published in the BKK Business Law Newsletter, the analysis explains that FIN 48 applies to all income tax positions, including decisions not to file returns, allocations among taxing jurisdictions, and classifications of income. The article notes that although FIN 48…

January 1, 2010

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Business and Financial Services

Family Limited Partnership and Family Limited Liability Company Valuation Discount Planning

Family limited partnerships and family limited liability companies can provide important estate planning and wealth transfer benefits, but only if they are operated carefully and consistently. In this Bean, Kinney & Korman article published in the BKK Business Law Newsletter, Jonathan C. Kinney explains that the IRS had become increasingly aggressive in challenging valuation discounts used in connection with FLPs and FLCs. The article notes that the IRS often questioned whether a gift was…

January 1, 2009