Family Limited Partnerships have been popular estate planning vehicles for decades due to both the tax and non-tax advantages that these vehicles can offer. As estate planning professionals are well aware, these vehicles can be subject to scrutiny by the IRS and have been challenged under a number of different theories over the past two decades. Case law has demonstrated that, if properly structured, these entities can be very useful vehicles, however, case law has also made abundantly clear that, if not properly structured and administered, negative tax consequences can result. The landscape in the partnership area is continuously evolving, and it is critical for any practitioner who plans with these vehicles to be well aware of developments in this area. In this recorded 90-minute webinar, our experts discuss the history of partnership planning, discussing various arguments that have been raised, both successfully and unsuccessfully, by the IRS over the years in its ongoing challenge of partnerships. Our speakers will also discuss practical tips for properly administering family limited partnerships. This is a recorded webinar that originally ran live on August 30, 2012. As an eLearning course, you must pass the final exam of this course to receive CPE credit.
Course Level: Intermediate
Course Prerequisites: None
Delivery Method: Self-study
After completing this course, you will be able to:
• Gain a historical perspective across the history of family limited partnerships – including landmark cases;
• Understand the evolution of partnerships and their impact in recent and current arguments such as the indirect gift theory and the step transaction doctrine;
• Know the theories supporting IRS challenges;
• Gain practical tips for partnership administration; and
• Know the consequences of failing under Section 2036 and Section 2703.
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