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Tax Law Update: December 2014

Tax Law Update: December 2014

• Recapitalization of family company caused taxable gift under IRC Section 2701—In Chief Counsel Advice 201442053, the Internal Revenue Service ruled that Internal Revenue Code Section 2701 applied to a recapitalization of a family-owned limited liability company (LLC), causing the taxpayer to have made gifts to her sons. The taxpayer established

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