ARSA RSS Feed ARSA LinkedIn
Ask ARSA Online Portal

IRS Proposes Significant Restrictions to Estate Tax Discounting Rules

On Aug. 4, the Internal Revenue Service (IRS) issued a notice of proposed rulemaking (NPRM) restricting the discounting of shareholder stock in family-owned operations for the purpose determining federal estate tax liability. Under current law, married couples are allowed $10.9 million in a lifetime exclusion for federal estate and gift taxes. Assets above the threshold are taxed at a 40 percent federal rate.

Traditionally, the IRS and the courts, for purposes of the federal estate and gift taxes, have permitted the valuation of privately-owned business interests to include a “lack of control” and “lack of marketability” discount because some stakes are worth less since they are harder to sell or represent a minority interest. The proposed rule, which applies to corporations, partnerships and limited-liability companies, disregards any restrictions on liquidation or redemption an heir uses to claim a valuation discount if that restriction either lapses after the transfer or the heir or heir’s family has the ability to remove the restriction after transfer. The IRS is also seeking to eliminate the lack of control discount to assignees.

The agency is accepting comments on its proposal until Nov. 2 and will host a public hearing in Washington, D.C., on Dec. 1.



More from ARSA

How’s Marshall?

On July 8, ARSA Managing Director & General Counsel Marshall S. Filler underwent successful heart surgery. He is recovering at home and is on track to continue his passion as…Read More

FAA to Restart Global Leadership Meeting

On July 20, the FAA announced plans to host its 8th Annual Global Leadership Meeting in Washington, D.C. on Sept. 22-23. The event will have both in-person and online attendance…Read More

Lawmakers Explore Aviation Workforce Diversity

The House Aviation Subcommittee held a hearing July 20 to discuss enhancing diversity in the aviation workforce. The witnesses were (click a name to download their written testimony): Rebecca Lutte,…Read More

Unpacking AD Authority

On July 2, ARSA requested clarification of the FAA’s authority to issue an Airworthiness Directive, questioning the April 22 posting of an AD against certain Uninsured United Parachute Technologies, LLC…Read More

Training – Parts Documentation Under the U.S.-EU MAG

To see all of ARSA’s work on the MAG, visit arsa.org/mag. For years, ARSA lead an industry wide effort to “smooth” implementation of parts documentation issues in the U.S.-EU Maintenance Annex…Read More
ARSA