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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Estate Planning

Date & Time
  • event Date

    Thursday, August 10, 2023

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    90 minutes

Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$297.00
CLE
CPE
ALL

This CLE/CPE course will provide trust and estates counsel with a thorough and comprehensive guide to the legal framework and challenges for valuations in estate and gift tax planning. The panel will discuss recent developments impacting valuations in estate planning, valuation discounts for estate and gift tax purposes, fractional interests, promissory notes, and challenges faced by estate planners implementing transfers and other strategies.

Faculty

Hubert Klein
Partner
Eisner Advisory Group, LLC

Mr. Klein is a Partner in the firm's Forensic, Litigation and Valuation Services Group, where he consults and provides services in matters including complex damages, business valuations, due diligence analysis, fraud and forensic investigations, matrimonial proceedings, lost profit calculations, shareholder disputes, insurance claims analysis, succession planning, and estate and gift planning. He has served as an agreed upon neutral expert and as an expert witness appointed by judges in the above types of matters and to issue reports for the courts on these cases. Mr. Klein frequently speaks to both business and civic groups on topics such as business valuation, forensic accounting, commercial damages and fraud.

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Chris Van Schooneveld
Director
Eisner Advisory Group, LLC

Mr. Van Schooneveld is a Director in the firm. With more than 8 years of experience, he is a well-rounded advisor with many areas of expertise and specializes in business and intellectual property valuations for estate and gift taxes, transactions, purchase price allocations and litigation matters. In addition, Mr. Van Schooneveld also provides litigation support and aids the firm’s audit practice with fair value measurements for financial reporting.

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Matthew T. Brown
Partner
Eisner Advisory Services, LLC

Mr. Brown is a Tax Partner in the Private Client Services Group (PCS). With a wealth of accounting, legal, and real estate experience, he provides business advisory and tax planning services for his clients. Mr. Brownt focuses on leading client engagements for individuals, privately held businesses, trusts, and estates. He advises on a wide array of tax matters including business start-up solutions, compensation structures, succession planning, wealth preservation strategies, and tax controversy work.

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Description

IRC Section 2704 and accompanying regulations have a significant impact on estate, gift, and generation-skipping transfer tax planning. Estate planners must recognize key issues relating to the valuation of interests in family-controlled entities and implement tactics to avoid loss of tax benefits.

The valuation discounts utilized by estate planners in passing down family-owned assets such as closely-held businesses require a complete understanding of complex rules and their impact on certain transfers for estate and gift tax purposes. Specifically, the rules treat lapse of voting or liquidation rights as an additional transfer and eliminate some discount valuation opportunities for restrictions on liquidation in determining the fair market value of a transferred interest.

In addition, the Treasury's Fiscal Year 2024 Greenbook includes proposed changes focused on Section 2704 as such applies to tradable assets, valuation discounts, "qualified real property" elected to be treated as special-use property, fractional interests, digital assets, and other key areas of focus. Estate planning counsel are advised to carefully consider any transfers of affected entities under current tax law and in light of proposed changes.

Listen as our experienced panel provides a critical look at recent developments impacting valuations in estate planning, valuation discounts for estate and gift tax purposes, fractional interests, promissory notes, and challenges faced by estate planners implementing transfers and other strategies.

Outline

  1. Contents of 2704 regulations
  2. Asset structures and valuation pitfalls to avoid
  3. Structuring transfers and key tax considerations
  4. Evaluating existing structures for holding family assets

Benefits

The panel will discuss these and other important issues:

  • What types of asset transfers are subject to Section 2704 regulations?
  • How does the treatment of lapses of voting or liquidation rights impact future transfers of family-owned assets into family limited partnerships or trust vehicles?
  • What issues must be considered for valuation discounts in transfers of closely-held businesses into estate planning vehicles?
  • What must estate planning attorneys and advisers consider for existing transfers and operating documents to minimize the tax impact of any proposed changes to the regulations?

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Identify the types of assets and transfers subject to the Section 2704 regulations limiting valuation discounts
  • Determine provisions in existing transfer structures and operating documents that may create tax payment and reporting obligations
  • Define what client transfers of non-controlling interests in family entities should be made in light of current regulations
  • Recognize the impact of proposed changes to Section 2704 provided in the Treasury's Fiscal Year 2024 Greenbook

  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite: Three years+ business or public firm experience with estate plan transfers of closely held business assets at mid-level within the organization, supervising other preparers/accountants. Specific knowledge and understanding of estate plan asset transfers, family-owned assets, limited partnerships and trust vehicles; familiarity with discount valuation and awareness of the basics of IRC 2704.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).