ARSA RSS Feed ARSA LinkedIn
Contact Us 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

Reminder: FAA to Present US-UK Implementation Procedures

On Dec. 2, the FAA will present updates regarding maintenance and airworthiness agreements between the United States and the United Kingdom that will become effective on Jan. 1, 2021. The…Read More

ARSA Remembers – Leo Weston

On Nov. 28, Leo Weston, whose passion for aviation began in high school, spanned the world and lasted until his final days, passed away at home in the presence of…Read More

Greasy Hands & Complex Problem Solving – 2020 Scholarship Winner C. Owen Ritzman

In November, ARSA awarded its 2020 scholarship to C. Owen Ritzman of Southern Utah University. Ritzman is an AMT student whose love of getting his hands dirty is matched only…Read More

Starting Young

The challenge of turning youthful energy into aviation career ambition demands early and constant contact with students. The best age to introduce a child to aviation and aerospace is “as…Read More

Looking Back to Move Forward on Workforce Policy

On Nov. 10, ARSA Vice President of Operations Brett Levanto participated in Global ATS-V. The international event was the online replacement for multiple aviation training trade shows overseen annually by…Read More
ARSA