Treasury Proposes New Regulations to Restrict Valuation Discount Planning

Prepare for a dramatic change in the scope of IRC Section 2704

From 2010 to 2013, the Treasury attempted to convince Congress to amend Internal Revenue Code Section 2704 to restrict the use of partnerships and other entities to generate valuation discounts.1 Neither house of Congress showed the slightest interest in making these changes. 

In 2013, the Treasury quit requesting these statutory changes, but it never gave up on its desire to tighten IRC Section 2704 to restrict valuation discount planning. On Aug. 4, 2016, the Treas

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