The valuation principles articulated in Ahmanson are equally applicable to the valuation of interests in family limited partnerships
with voting stock being analogous to a general partnership interest in a family limited partnership
, and with nonvoting stock being analogous to a limited partnership interest.
Focus on Gifts Given Through Family Limited Partnerships
(2) Although the family limited partnership
is an innovative use of existing laws regarding limited partnerships, it should always be established for legitimate business and non-tax estate planning purposes.
Then, its alternate food groups, the family limited partnership
and tax return preparation, became dangerous to eat.
The use of a family limited partnership
as an estate-planning
Velis had been leasing the property and building since its recent sale to the Uy Family Limited Partnership
. The property sold for $2.4 million, according to the Whatcom County treasurer's office.
1060, 388, 754, 743, and 734 (the SSVS is not limited solely to these sections); determination of the value of a family limited partnership
; consequences of discharge of indebtedness pursuant to IRC Sec.
(2) Although the IRS has asserted that a taxable gift can arise upon the contribution of capital to a family limited partnership
, this argument was rejected where the partnership agreement allocated income and expenses on a pro rata basis based on the partners' contributions to the partnership.
The first step was to establish the Family Limited Partnership
. George wanted to make sure the FLiP would operate smoothly after his death, so he put several restrictions in the partnership agreement such as:
In one of the scenarios, they demonstrated how gifting minority interests to the children, creating a family limited partnership
to hold business real property, and doing a sales-and-leaseback of the principle residence provided a savings of $2 million dollars in death taxes to the heirs of a family-owned business.
The property sold for $3,700,000 to Janosz Family Limited Partnership
of San Diego.
The family limited partnership
must pass the "assignment-of-income principle" test to be treated as such.