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327 results found


Proskauer Rose LLP | USA | 21 Jan 2010

Tax Court upholds defined value gift in which LLC interests given to the donor’s children and charities

On the heels of Christiansen, the Tax Court upheld a defined value clause over the IRS’ public policy objections, this time in the context of a part-gift, part-sale of LLC interests.


Loeb & Loeb LLP | USA | 14 Sep 2009

More mixed results in litigation of family limited partnership cases

The enormous tax dollars at stake in connection with valuation discounts for estate and gift tax purposes is evidenced by the never ending stream of family limited partnership cases.


Loeb & Loeb LLP | USA | 26 Aug 2008

Taxpayers enjoy success in recent family limited partnership cases

Many recent court decisions concerning family limited partnerships or limited liability companies (“LLCs”) have involved “bad facts making bad law.”


Reed Smith LLP | USA | 24 Oct 2007

IRS establishes safe harbor for Section 45 credits claimed by partners of wind energy partnerships

On October 19, 2007, the IRS released Revenue Procedure 2007-65, which establishes safe harbor rules under which the IRS will respect the allocation of Section 45 wind energy production tax credits among the partners of a partnership that owns a qualified wind energy facility.

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