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The Internal Revenue Service has almost literally thrown the (Internal Revenue Code) book at family limited partnerships (FLPs), seeking to negate their validity, and thereby knock out discounts and reap higher tax payments. It has had some of its greatest success against FLP discounts with IRC Section 2036(a).1 In Strangi II,2 the Tax Court's second ruling on Strangi,3 the IRS argued successfully

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Wealth Management logo in a gray background | Wealth Management

Edward A. Renn & N. Todd Angkatavanich

The Internal Revenue Service has almost literally thrown the (Internal Revenue Code) book at family limited partnerships (FLPs), seeking to negate their validity, and thereby knock out discounts and reap higher tax payments.

It has had some of its greatest success against FLP discounts with IRC Section 2036(a).1

In Strangi II,2 the Tax Court's second ruling on Strangi,3 the IRS argued successfully that the full value of an FLP's assets should be included in the decedent's estate pursuant to Section 2036(a)(2) because the decedent maintained a slight interest in the controlling entity of the FLP. This small interest was not even enough to control the decisions of the entity. Still, the court determined ...

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About the Authors

N. Todd Angkatavanich

Principal, National Tax Department, Ernst & Young LLP, Private Client Services Group

N. Todd Angkatavanich is a principal in the National Tax Department of Ernst & Young LLP, in the Private Client Services Group. His practice is focused on tax, trusts and estates, and business succession matters for affluent individuals and their families. He regularly advises domestic and international families and family offices with respect to creating trust and related business structures to preserve, protect and grow family wealth for multiple generations in a tax efficient manner. 

Todd has been published in Trusts and Estates, Private Wealth and Estate Planning Magazine, ACTEC Journal, BNA Tax Management, Private Asset Management and other publications.  He is a member of the Editorial Board for Trusts & Estates Magazine.  He is also a member of the Advisory Board for BNA/Tax Management Estates, Gifts and Trusts Journal. 

Todd is a frequent speaker on estate planning topics such as Family Limited Partnerships, Business Succession Planning and related Chapter 14 issues.  He has given presentations, webinars and teleconferences for various organizations including the Heckerling Estate Planning Institute, the ABA Section of Real Property Trust & Estate Law Spring Symposia, Trusts & Estate Magazine, BNA/Tax Management as well as numerous estate planning councils, CPA Societies and professional organizations.  Todd has been quoted in articles that have appeared in Barron's, Bloomberg Businessweek, The Boston Globe, The Miami Herald, MSN Money and other publications.

Todd is the recipient of the 2012 "Private Client Lawyer of the Year" Award, FOR (Family Office Review) Awards, North America, Chicago.

Todd is a vice-chair of the Business Planning Group - Business Investment Entities Committee of the American Bar Association, Real Property, Trust & Estate Law Section.