McGuireWoods partners Ron Aucutt and Dennis Belcher, co-chairs of the firm’s Private Wealth Services Group, discussed proposed Internal Revenue Service rules to rein in estate valuation discounts in an Aug. 2 article in Bloomberg BNA’s Daily Tax Report. Aucutt also commented on the proposed regulations for Tax Notes, which provides daily news, analysis and commentary on issues important to tax professionals.
The Bloomberg BNA story extensively quotes Aucutt and Belcher on proposed regulations to add a new class of restrictions that would be disregarded in valuing transfers of family interests. Belcher told the Daily Tax Report he was pleased that the IRS and U.S. Department of the Treasury set a date for the final regulations to take effect after being published in the Federal Register. “It will give all of us an opportunity to go through the plans that we’ve done in the past and see where we need to make any adjustments or whether we need to take advantage of the current rules before these become the existing rules,” he said.
In the Aug. 3 Tax Notes article, Aucutt explained that the rules are aimed at taxpayers who put valuable property into certain entities such as family-owned partnerships or corporations to reduce the property’s value. “To the extent that the value of the interest in entity in the aggregate is less than the interest in the value of the property, the IRS sees value as escaping the estate and gift tax, and that’s what they are after,” Aucutt said.
McGuireWoods’ nationally recognized Private Wealth Services Group received a top ranking in the first High Net Worth Guide published by Chambers and Partners, the respected global legal services directory that consistently ranks the firm among the best in the United States for wealth management.
The firm will host an Aug. 11 webinar on the proposed Section 2704 IRS rules.