eFamily Limited Partnerships (FLPs) have become an excellent tool for individuals
to transfer wealth to lower generations while minimizing potential consequences of estate and gift taxes. As FLPs have become more susceptible to attack by the IRS, knowing how to create a Family Limited Partnership that survives an audit has become crucial for the sophisticated estate planner. This informative manual explains what you need to know about FLPs, including:
- Reasons and advantages for creating a FLPs
- echniques for creating FLPs
- Sophisticated planning opportunities and estate freeze techniques that use FLPs
- Structuring FLPs to survive an audit
- Avoiding 2036 pitfalls in a FLP
- Charitable planning opportunities through FLPs
- Strategies when defending FLPs in IRS examinations, Appeals and in Litigation
Summary of Contents:
Some of the Best Family Limited Partnership Planning Ideas We See Out There © Introduction; Best Non-tax Planning Idea – or Why Investment Professionals Love Limited Liability Companies and/or Limited Partnerships; Best Family Limited Partnership Planning Idea – Sell It; Best Valuation Idea for Family Limited Partnership Interests – The Defined Value Allocation Formula Clause; The Best Legal Argument Against Application of I.R.C. Section 2036 to a Decedent’s Partnership Interest – I.R.C. Section 2033 Inclusion Supersedes I.R.C. Section 2036 Inclusion; The Best GST Planning Idea for a Family Limited Partnership – The Possible Use of Leveraged GRAT; The Best Post-Mortem Family Limited Partnership Planning Idea (and Good Insurance Planning Idea) – the Note “Freeze” Partnership The Best Lifetime Charitable Planning Idea – Partnership or a Limited Liability Company, Creates a Charitable Remainder Trust with the Partnership Units Eventually Being Sold to a Grantor Trust; Best Testamentary Charitable Planning Idea for the Family Limited Partnership – The Leveraged Buy-Out Charitable Lead Annuity Trust; Best Insurance Planning Idea (and a Very Good Estate Planning Idea) – The Leveraged Reverse Freeze with a Cascading Sale of Growth Partnership Interests; The Best Ideas for Allowing a Client to Be in Control of Family Limited Partnership in the Context of I.R.C. Section 2036(a)(2) – Revenue Ruling 73-143, 95-58 and 81-15 | Examination, Appeals and Litigation of Federal Tax Controversies – Family Limited Partnerships; Examination; Appeals; Litigation.
Number of Pages: 248
