IRS Released Its Positions Regarding Limited Liability Companies

Business Valuation Update BVLaw
Legal and Court Case Update
December 8, 2000

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estate and gift taxation
FSA 200049003

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.

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FSA 200049003

Full Text of Court Cases
December 8, 2000

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 ...