Valuation discounts still apply to transfers of interests in a single-member entity. But the fact that the Tax Court produced so many opinions in this one case makes advisors a little nervous
Is the transfer of an interest in a single-member limited liability company (LLC) — a “disregarded entity” — valued as a transfer of a proportionate share of the underlying assets owned by the LLC or as a transfer of an interest in the LLC subject to valuation discounts for lack of marketability and control? According to a recent en banc Tax Court decision, Pierre v. Commissioner,1 a disregarded entity is not to be forgotten. The taxpayer, Suzanne Pierre, received a $10 million inheritance ...
All Access Premium Subscription
Your subscription will include 12 months of Trusts & Estates magazine, access to premium content on WealthManagement.com, and Trusts & Estates plus iPad app.