Featuring (click image for more information):

John Porter Attorney at Law Baker Botts LLP

Why You Should Attend

In the August, 2011 issue of BVUpdate™ John Porter noted "recent court decisions have dealt a blow to the effectiveness of family limited partnerships (FLPs) for transfer tax purposes, particularly when the partnership formation and funding fail to respect state law requirements. In these cases, the IRS has successfully attacked the FLPs—often nullifying any valuation discounts—by focusing on their lack of economic substance/business purpose, or characterizing the asset transfers as indirect gifts/gifts-on-formation."

In "Family Limited Partnerships: The Current Landscape," the first installment of BVR's Online Symposium on Estate & Gift Tax Porter, an expert attorney and CPA, joins us to discuss the changing landscape of FLPs. From how recent IRS tactics and court cases have affected the regulatory treatment of FLPs to how appraisers should approach these valuation assignments, Porter will address what everyone must know when operating in this challenging and changing space.

Agenda

• Overview
• Basic valuation principles
• Dealing with the IRS's arguments regarding FLPs
• IRC § 2073 argument
• The indirect gift/gift on formation argument
• Disregarded entities/step transaction
• Annual exclusion gifts
• IRC § 2036(a)
• Significant § 2036 cases
• Appeals coordinated issues settlement guidelines
• Formula transfers
• Value adjustment clauses
• Value definition clauses
• Recent decisions favor the use of formula clauses
• Gift tax reporting
• Income tax issues
• Graegin notes
• Various valuation adjustments
• Privileges in the estate planning context
• Working with attorneys, working with appraisers
• Where are we now and where are we headed?

Learning Objectives

• Learn how IRS regulations - and the courts' interpretations of those regulations - have and will impact FLP valuations
• Understand how formula clauses and other strategic language fits with FLP valuations, assessments, and IRS reviews
• Learn how Graegin Notes fit in estate & gift valuations and regulations
• Clarify best practices with regard to the appraiser's role in FLP valuations, litigations, depositions, and other actions

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Admission to this program includes one CPE certificate for one individual. Any additional listeners requesting CPE must pay a processing fee assessed at the completion of the online CE survey for this course.

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CPE Information

Prerequisites: Knowledge of Business Valuation
Program Level: Advanced
Preparation Required: None
Delivery Method: Group Internet-Based
Recommended CPE: 2 Credit Hours (Taxes and Specialized Knowledge & Applications)

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