Structuring and Operating Family Limited Partnerships: Asset Protection and Income Tax Reduction
Shifting Income Tax Burden to Lower-Taxed Family Member Partners, Application of Section 199A, Valuation Discounts
Recording of a 90-minute CLE/CPE webinar with Q&A
This course will provide tax advisers with a practical guide to structuring and operate Family Limited Partnerships (FLP) in light of the withdrawal of the proposed Section 2704 valuation regulations and the new tax reform bill. The panel will discuss the income tax and asset protection benefits of FLPs, detail how to withstand IRS scrutiny of transfers and operations and address the interplay between estate planners and income tax advisers, in particular concerning planning to obtain a step-up in basis upon death.
Outline
- Using FLPs for asset protection and business continuation/succession planning
- Structuring and funding options
- Discounting options after rescission of Section 2704 regulations
- Application of Section 199A deduction to FLPs
- Income tax minimization opportunities
- Business operation challenges
- Business purpose rules
- Using FLPs with trusts and other wealth transfer vehicles
- Distribution strategies
- Maintaining cash flow for transferor general partner
Benefits
The panel will discuss these and other relevant topics:
- How does the new Section 199A pass-through deduction apply to family limited partnerships?
- Withstanding IRS scrutiny in operating an FLP for non-tax reasons under the business purpose rules
- Using distributions to shift income tax burden to limited partner family members with lower marginal income tax rates
- Strategies for funding FLPs through nontaxable transfers and sales
- Discounting factors under the new exemption amount in light of the rescission of the proposed Section 2704 regulations
Faculty
Diana Myers
Tax Counsel and Wealth Planner
Northern Trust
Ms. Myers works to keep clients and colleagues up-to-date on leading tax planning strategies and wealth transfer... | Read More
Ms. Myers works to keep clients and colleagues up-to-date on leading tax planning strategies and wealth transfer techniques. Before joining Northern Trust, she was a tax associate at Baker and McKenzie, where Ms. Myers represented private equity funds and individuals making cross-border investments and negotiated M&A agreements for public companies.
Close
Scott D. Weaver
General Counsel and Chief Fiduciary Officer
Willow Street Group
Mr. Weaver is a trust and estate attorney serving both domestic and international families and their advisors. Before... | Read More
Mr. Weaver is a trust and estate attorney serving both domestic and international families and their advisors. Before joining the firm, he practiced with Gonnella Adamson P.C. where he focused on tax, business and estate planning. Prior to law school, Mr. Weaver worked in the Emerging Market Economies section of the Federal Reserve Board as a Senior Research Assistant where he assisted with research, forecasting and modeling of the Chinese economy. In this role, he also assisted with the preparation of briefing materials used by former President George W. Bush at the Second Strategic Economic Dialogue with the People’s Republic of China.
Close