This presentation addresses critical aspects of planning, reporting on a transfer tax return, and addressing on audit a number of valuation issues related to family limited partnerships, limited liability companies, S Corporations, and other hard to value assets. The discussion will include certain sophisticated estate planning techniques such as sales to intentionally defective grantor trusts, formula transfers, GRATs, self-cancelling installment notes, private annuities, and promissory notes.
• To familiarize the audience with the issues surrounding these issues
• Provide advice with respect to reporting the transfers in tax returns and dealing with them in connection with transfer tax audits.
• We will also discuss Treasury/IRS guidance and audit issues with respect to these issues.