Summary
The Internal Revenue Service stated its positions regarding the recapture of the value of assets transferred to a closely held LLC for gift and estate tax purposes. It holds that the economic substance doctrine applies, IRC sec. 2703(a) is applicable, IRC ...
FSA 200049003
PDF, Size: 126 KB
See Also
IRS Released Its Positions Regarding Limited Liability Companies
The Internal Revenue Service stated its positions regarding the recapture of the value of assets transferred to a closely held LLC for gift and estate tax purposes.