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Effective Estate Planning with
Family Limited Partnerships & Limited Liability Companies
by
Author: Leo J. Cushing, Esq., CPA
Drafting FLP's & LLC's to Withstand IRS Examination - 174 pages
- Rev. Rule 93-12: Discount Planning for Transfers Between Family Members
- IRC 2036 (a)(1) & IRC 2036 (a)(2) - Who should be the General Partner?
- The bona fide Sale Exception of 2036
- Is there a gift on Formation
- Is the LLC a buy/sell agreement under IRC 2703
- IRC 2704 What are permitted applicable restrictions?
- Learn how to value the FLP and LLC interests
- Recent Valuation Cases
- Drafting Operating Agreement to be eligible for the present interest exclusion
- Operational and Dissolution issues
- Avoiding Gain on Formation
- IRC 704 Allocations at the time of Distributions
- Inside basis and outside basis computations
- IRC 754 Step-Up Basis Rule
- Structuring the partnership and LLC to obtain and preserve valuation discounts
with marketable securities to reduce values up to 30%.
- Structuring an estate plan with QTIP Trusts to Obtain Discounts on the first
death and the second death in connection with planning for married couple.
- Special Presentation on Delaware Series LLC's (Iowa and Illinois follow
Delaware and implement Series LLC Statutes).
- Review, Questions, Discussion & Analysis
Includes Sample FLP (21 pgs) and Sample LLC Operating Agreements (17 pgs).
$145.00
Price includes (Shipping/Handling)
(For 5 or more, call 978-468-6528 for quantity discounts)
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