Restricted Management Accounts

Although use of restricted management accounts (RMAs) is far from widespread, the Internal Revenue Service seems to have declared its intention to shut them down so it doesn't have to fight valuation discounts on two fronts: RMAs and family limited partnerships. But a revenue ruling does not have the force of law and a revenue ruling's conclusions can be disputed in court. In Revenue Ruling 2008-35,

Although use of restricted management accounts (RMAs) is far from widespread, the Internal Revenue Service seems to have declared its intention to shut them down so it doesn't have to fight valuation discounts on two fronts: RMAs and family limited partnerships. But a revenue ruling does not have the force of law and a revenue ruling's conclusions can be disputed in court.

In Revenue Ruling 2008-35, I.R.B. 2008-29 (July 21, 2008), the IRS held that an interest in an RMA will be valued

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