Estate Planning for Owners of Closely Held Business Interests (Portfolio 809)

Description

Bloomberg Tax Portfolio, Estate Planning for Owners of Closely Held Business Interests, No. 809, is designed as a guide to the lifetime and post-mortem estate planning techniques primarily applicable to the owners of interests in closely held businesses.

Detailed consideration is given to various kinds of buy-sell agreements, including cross-purchase and stock redemption agreements; the gift and estate tax rules governing the lifetime disposition of closely held business interests, with special emphasis on §§2701-2704; the use of recapitalizations, charitable bail-outs, and private annuities to accomplish retirement, gift, and estate planning goals; §§303 and 6166 “relief” provisions concerning the payment of estate tax where the estate consists in significant measure of an interest in a closely held business; the rules which apply to subchapter S corporations; and special considerations when using a limited liability company.

This Portfolio may be cited as Mezzullo, 809 T.M., Estate Planning for Owners of Closely Held Business Interests.

Table of Contents

I. Introduction
II. Transfer of Closely Held Business Interest
III. Payment of Estate Taxes
IV. Estate Planning for S Corporations
V. Estate Planning for Partnerships and LLCs Taxed as Partnerships