The Wait is OverThe Wait is Over

In many instances, the anticipation of an event is worse than the reality. However, the early August release of the proposed regulations under Internal Revenue Code Section 2704 (proposed regs) surprised the estate-planning community with how far they reached. The Treasury took advantage of the broad authority Congress provided in IRC Section 2704 to issue regulations establishing that “other restrictions shall be disregarded in determining the value of the transfer of any interest in a corporation or partnership.”¹ Based on years of audit attention and the large number of Tax Court cases involving family limited partnerships, the expectation was that the proposed regs would be aimed at entities holding investments or marketable securiti...