Family Ltd Partnership, or

Family LLC

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Contents of this article
  1. The Question
    1. Question
  2. The Answer
    1. Answer

    2. Preface & Executive Summary

  3. Commentary

    1. Commentary

    2. Successful Internal Revenue Service Arguments

    3. Case and Ruling Summary

    4. Present Interest Discussion

    5. Internal Revenue Service Position and Arguments

    6. Court’s Statements

    7. Highlights and Quotations From The Case

    8. Problem Areas of the FLP Agreement Language

  4. Reprint from Lawyers Weekly

    1. Reprint from Lawyers Weekly “Family LLC Interest Gets No Gift Tax Exclusion”

    2. Introduction

    3. No 'Present Interest'

    4. What To Do

    5. "Right of first refusal."

    6. Temporary sell-back or withdrawal right.

    7. Temporary right to sell

    8. Cash gifts

    9. Mandatory distributions

    10. 'Choose Your Strategy'

    11. No Exclusion For LLC Interests?

  5. Sample FLP Provision

  6. Authorities Section

    1. Authorities Section

    2. Case Identification Hackl v. Internal Revenue Service

    3. Background

    4. OPINION

    5. BACKGROUND

    6. PERSONAL, EDUCATIONAL, AND OCCUPATIONAL BACKGROUND

    7. INITIATION OF TREE FARM INVESTMENT

    8. FORMATION OF TREECO, LLC, AND GIFTING OF INTERESTS THEREIN

    9. OPERATIONS OF TREECO, LLC, AND SUCCESSOR ENTITIES

  7. DISCUSSION

  8. I. SETTLED AND DISPUTED ISSUES

  9. II. STATUTORY AND REGULATORY LAW

  10. III. CASE LAW DEVELOPMENT

  11. IV. CONTENTIONS OF THE PARTIES

  12. V. ANALYSIS

  13. PLR 199415007 12/12/1994

  14. The Solution
    1. Solution
    2. Sample FLP Provision
  15. Client Kit - UNDER CONSTRUCTION
    1. Kit to Prepare for your adviser
    2. Do It Yourself or Get the Kit
    3. Tools
    4. Sample Documents
  16. Adviser Kit  - UNDER CONSTRUCTION
  17. Kit for the adviser
  18. Related Articles

  19. Family LP Table Of Contents - Contents of this Category & Related Topics

  20. Family Partnerships - Table of Contents FLP or Family LLC

  21. family limited partnership client letter

  22. Family Ltd Partnership - Basics Article

  23. Family Limited Partnerships - Client Letter, Following Completed Gift Rules

  24. Family Limited Partnership - When To Use

  25. Family Wealth Retention and Family Asset Protection

  26. The Family Limited Partnership- A Planning Technique

  27. Family Limited Partnership - Annual Exclusion

  28. Family Ltd Partnership - Asset Protection

  29. Family Ltd Partnerships - Or Loans, A Comparison

  30. Family Ltd Partnership - Estate and Gift Tax Impact

  31. Family Ltd Partnerships - Gifts of Interests

  32. Family Ltd Partnership - Income Tax Impact

  33. Family Limited Partnership - Warnings

  34. Family Ltd Partnership Pitfalls - IRS Attacks 12-2000

  35. Family Limited Partnership - private letter ruling 9751003

  36. FLP - Problems and Questions

  37. Family Ltd Partnerships - Study IRS Attacks

  38. Family Limited Partnership - Successful Transfers

  39. Famiily Lmiited Partnership - Transfer Errors

  40. Family LP ~ USTC Approvals