Article Abstract:
The IRS has provided a tax-favored multiple employer trust exception under IRC section 419A(f)(6) to the policy it announced in Notice 95-34 that disfavors use of welfare benefit plans. Welfare benefit plans are subject to abuse when employers overfund the plans to defer compensation to shareholders and executives. The exception grants current deductions for legitimate welfare plans that use actuarial contribution valuations and are intended to reduce the risks faced by individual employers.
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Article Abstract:
Family limited partnerships came under attack by the IRS, the Tax Court, and the Clinton Administration in 1997 and 1998. Highly public advertisements by practitioners of the tax benefit value of such investment partnerships led to governmental scrutiny as well as abusive uses. The life of these partnerships is not likely long and practitioners should carefully plan and document the structuring of existing and newly created entities.
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Article Abstract:
Valuation of businesses for purposes of estate or gift taxes can be accomplished by reference to IRS Revenue Ruling 59-60 which provides practitioners with eight factually-based factors. Closely held business interests are particularly difficult to value. The Tax Court may reject valuations which are apparently consistent with IRS rules, as it has in several cases including Buffalo Tool & Die Manufacturing Co. v. Commissioner.
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