Family Limited Partnerships, Limited Liability Companies and Tenant-In-Common Interests
One estate planning strategy that is often recommended by attorneys, financial planners and accountants is placing appreciating assets into a family limited partnership or a limited liability company. Gifts of non-controlling interests in these entities are made typically to members of the younger generation so that the appreciation in the value of the assets does not accrue to the older generation where the estate tax liability is likely to occur sooner. Clients taking advantage of our services find that:
- We are in a good position to advise their attorneys as to the provisions in the partnership agreement or operating agreement that will minimize the value of any gifts that will be made of non-controlling interests in the limited partnership (“LP”) or limited liability company (“LLC”).
- We are very familiar with how the IRS and the courts view the structure and valuations of LPs and LLCs; we address these views in our valuation analysis and report.
- We have extensive experience in discussing the valuation of interests in LPs, LLCs and tenant-in-common interests with many of the local IRS auditors and appeals officers. We are available to help advisors negotiate a favorable settlement should there be an audit of a gift.
- Our comprehensive reports contain extensive explanations and detailed analysis, far more than the typical valuation report that is produced elsewhere.