Resources on Section 2704 Valuation Regulations 

On August 2, 2016 the Treasury Department released the long-awaited 2704 proposed valuation regulations that may limit the availability of estate and gift tax valuation discounts.  The proposed regulations would amend section 25.2701 to address what constitutes control of a limited liability company (LLC) or similar entity, address deathbed transfers that result in the lapse of a liquidation right and clarify the treatment of a transfer that results in the creation of an assignee interest, refine the definition of the term “applicable restriction” by eliminating the comparison to the liquidation limitations of state law, and address restrictions on the liquidation of an individual interest in an entity and the effect of insubstantial interests held by persons who are not members of the family. 

Keep up with the latest legislative/regulatory and advocacy efforts

News & Advocacy
Audio Podcast: AICPA Calls on IRS to Withdraw and Re-Propose Estate Valuation Discount Regulations

Catch up on the latest news with these podcasts from Bob Keebler:
  • A Window of Opportunity for CPAs to address this with their individual, family, and closely-held business owner clients.
  • Interview with Jonathan Battmachr on:
    • Historical Context on Discounting Techniques
    • Short-term Planning for Long-Term Consequences
    • How Specific Entities are Impacted
    • When You Should Act 
  • Interview with Larry Brody on Action Steps for Insurance Advisers
    • Overview of Regulation Implications
    • Short Term Actions Insurance Professionals Should Take
    • Long-Term Insurance Implications to Consider 
  • Interview with Dennis Belcher on:
    • Why CPAs should be concerned
    • Magnitude of the changes from a mathematical perspective
    • Overview of the proposed regulations
    • Strategies to discuss with clients
  • Martin Shenkman delivers a  practical planning podcast on how practitioners can use GRATs in light of the proposed regulations.

Proposed Valuation Discounts – What CPAs Need to Know
Recording | Slides | Handout

Other Resources

Suggested Disclosure Statement*
*As many on the AICPA 2704 Task Force read it, the Trump Administration executive order (M-17-16), implementation of regulatory freeze, only withdraws regs that were not yet published. 
It is our impression that the section 2704 proposed regs are on hold for 60 days, and no final regs can come out before 3/23/17.  
The section 2704 proposed regs are not yet withdrawn, so the AICPA task force thinks the disclosure statement still applies while the proposed regs are still in existence.



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