BarbriSFCourseDetails
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Course Details

Course Information
  • smart_display Format

    Live Online with Live Q&A

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax and Accounting

Date & Time
  • event Date

    Wednesday, May 7, 2025

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    110 minutes

Credit Information

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$197.00

This course will provide trust and estate advisers who work with high net worth individuals and partnerships with a thorough review of family-controlled entities and valuation discounts. The speakers will discuss the current landscape of family entity structures; valuation discounts for lack of marketability, lack of control, and minority interests; and the interplay between estate planning and income tax, particularly concerning planning to obtain a step-up in basis upon death.

Faculty

Weeg Christopher
Shareholder
Comiter Singer Baseman & Braun, LLP

Mr. Weeg, partner with Comiter Singer, is Board Certified in both Tax Law and in Wills, Trusts and Estates and is also a licensed CPA. His law practice includes drafting wills and trusts; advising on income, gift, estate, and GST tax issues; forming business and nonprofit entities; and probating estates. Mr. Weeg is experienced in the preparation of gift and estate tax returns, representation of executors in all phases of estate administration, and creating comprehensive estate plans tailored to meet clients’ personal objectives in a tax efficient manner. He is licensed to practice law in Florida and Texas.

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Description

Consolidating assets in an FLP or other family entity, as well as obtaining other nontax benefits, remains an effective tool to manage assets and potentially reduce estate, gift, and GST tax through valuation discounts for lack of control and lack of marketability. Most recently, the Tax Court in Estate of Fields v. Commissioner, TC Memo 2024-90¸analyzed a deathbed FLP that resulted in the application of Section 2036 (as well as the double inclusion issue posed by Section 2043).

In Estate of Nancy H. Powell v. Commissioner, 148 T.C. No. 18 (2017), the Tax Court applied Section 2036(a)(2), the less common arm of Section 2036. It stated that since, in conjunction with the other partners, the decedent could dissolve the partnership, the decedent had retained an interest in the assets, which were consequently pulled back into the estate at their date of date value. This ruling has caused trust and estate planners to take a fresh look at FLPs and closely held entities in estate plans. Trust and estate advisers working with family wealth need to understand how to consolidate and protect these assets by transferring assets to closely held structures, which may be eligible for valuation discounts for transfer tax purposes.

Listen as our panel of wealth transfer experts explains using closely held family entities and valuation discounts to preserve family wealth.

Outline

  1. Estate planning with closely held family structures
  2. Family-held entity structures
  3. Tax and nontax benefits
  4. Valuation discounts
  5. Section 2704
  6. Relevant cases
  7. Reporting FLP transfers on federal gift tax returns

Benefits

The panel will discuss these and other important issues:

  • How Fields and Powell, and other decisions influence estate planning
  • Walkthrough of a recent FLP case
  • Section 2704 and its impact on FLPs, LLCs, and other family-controlled entities
  • Applying lack of control and lack of marketability discounts
  • Determining clients best suited for FLPs and valuation discounts

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Understand estate planning with closely held family structures
  • Differentiate between entities available to use as family entities
  • Distinguish between tax and nontax benefits
  • Discern the impact of IRC 2704 on FLPs, LLCs, and other controlled family-entities
  • Determine client's best suited for FLPs and valuation discounts
  • Recognize different types of transfers

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).