Going once...Going twice...Valuation Discounts
The IRS and Treasury Recently Issued Broad Proposed Section 2704 Regulations, which if adopted, would curb minority valuation discounts. A public hearing will occur Dec 1st, with final regulations potentially effective by early 2017.
- What do financial planners need to know and communicate to their high net worth clients immediately, to solidify any existing plans, or create new plans and entities, ahead of final regulations?
- What can planners and their clients expect the future to bring re: valuation discounts?
Discussion Moderator:
Tom Maguire
Subject Matter Experts and Panelists:
Ira Feldman, Les Raatz , Larry Gibbs
Implications that will be explored during Panel Q&A:
- What does this mean to clients with taxable estates (liquid or not)?
- What does this mean to clients with illiquid or unusual assets as the core of their net worth, difficult family dynamics and blended families?
- What does this mean for closely held or family business?
- How would a financial planner model the financial plan potential impact for clients before and after these Regs are final?
- How should a financial planner communicate these issues to clients and peers?
- What planning tools will continue even if the new regs are fully adopted?
- 5 steps to take tomorrow morning to identify and support clients who may be most impacted and have reason to make haste
Additional Reommended References and Resources:
Ira Feldman/James Polese Article: “Current Challenges to the Family Limited Partnership…”
Dickinson Wright Client Alert: “End to Discounts…”
Gibbs: “Practical Procedures…”
Steve Akers, Bessemer Trust: “Proposed Regs…”
Format:
3:15 – 3:35p History of Valuation Discounts and the Business and Common sense rationale for them: Gibbs, Feldman
3:35 – 3:55p IRS attacks on Valuation Discounts: A primer on the big winners and consistent losers: Raatz, Gibbs
3:55 – 4:15p Proposed Regs: what they are, how they impact valuation discounts, what they don’t affect: Feldman, Raatz
4:25 – 5:30p Planning Implications and Practice Implications Discussion - All panelists, moderated discussion
5:30- 6:00p Optional: additional Q&A with panel and moderator as desired, while mixer begins
Continuing education:
2 hours, Pre-certified for CFP® professionals and Arizona Life Insurance Professionals,
Should also quality for JD, CPA, AEP, and other financial, legal, tax, and appraisal professionals
