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. 

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