Insights

Non-controlling family partnership interests with limited marketability have long been discounted for federal gift and estate tax valuation purposes, reducing their deemed fair market value and the gift and estate tax attributable to such interests. The income tax tradeoff for a partnership interest held until death is that the income…

In a recent ruling, the IRS confronted a partnership serving as a management company for investment partnerships and funds. Management fees were its sole source of income. The management company paid reasonable compensation subject to employment or self-employment taxes to its owner-managers. Following a planning technique available to S corporations,…

The Internal Revenue Code prescribes minimum imputed interest rates and time-value-of–money factors applicable to certain loan transactions and estate planning techniques. These rates are tied formulaically to market interest rates. The Internal Revenue Service updates these rates monthly. These are commonly applicable rates in effect for September 2014: Short Term AFR…

Private equity firms sometimes waive management fees payable by portfolio investment entities or funds in exchange for new partnership interests in the entities or funds. In theory, the practice is fair because the fee recipients surrender a certain stream of income in exchange for a partnership “profits interest” that may…

On behalf of a client, Williams Parker recently obtained a Technical Assistance Advisement from the Florida Department of Revenue (the “Department”) that leases of nursing homes and assisted living facilities are exempt from sales tax to a greater degree than currently provided in the Florida Administrative Code. Oftentimes, the operator…