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| July 2009 | ||||||
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| In This Issue | ||||||
| Favorable FLP Case | ||||||
| Tax Court upholds 35% valuation discount | ||||||
| on transfer of securities. | ||||||
| Proposed Regulations Value "Graduated" GRATs | ||||||
| IRS publishes supplemental regulations | ||||||
| explaining inclusion of graduated GRATs | ||||||
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| Favorable FLP Case | Upcoming Events | |||||
Mrs. Miller's deceased husband and her eldest son spent years researching and investing in securities. By the time Mr. Miller passed away in 2002, his gross estate was $7.7 million and comprised mostly of marketable securities. After Mrs. Miller's passing in late 2003 the Tax Court was asked to determine whether the 35% valuation discount on securities transferred to the FLP in 2002 and 2003 should be allowed rather than bringing the assets back into her estate. |
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September 2009 | |
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| Planning Opportunities for High Net Worth Individuals | ||||||
| By Appointment Only | ||||||
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| Past Articles | ||||||
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Treasury Greenbook: A Technical Guide to the Administration's Budget Proposals |
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| Proposed Regulations Value "Graduated" GRATs | ||||||
On April 30, 2009, the IRS published supplemental regulations that explain the inclusion of graduated GRATs or similar trust. The regulation included two examples. The first example, assumes trust income is paid to a parent and a child. The second example, describes a GRAT with an initial payment and 20% increasing payment for a term of 5-years. |
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