Section Newsletters

Articles From Bruce A. Johnson

Proposed 2704 changes meet stiff resistance at IRS hearing By Bruce A. Johnson Trusts and Estates, January 2017 Since the tax court decision of Kerr v. Commissioner, the IRS has been concerned that certain loopholes exist in IRC 2704 that allow taxpayers to gift interests to family members in entities that have no business purpose and allow the transfer of wealth without due consideration of the value to the transferor.
Proposed 2704 changes meet stiff resistance at IRS hearing By Bruce A. Johnson Business Advice and Financial Planning, December 2016 Since the tax court decision of Kerr v. Commissioner, the IRS has been concerned that certain loopholes exist in IRC 2704 that allow taxpayers to gift interests to family members in entities that have no business purpose and allow the transfer of wealth without due consideration of the value to the transferor.
Proposed IRS regulations may eliminate long-standing discounts for family-owned businesses By Bruce A. Johnson Federal Taxation, November 2016 The Internal Revenue Service released proposed regulations on August 2, 2016 that would modify and expand Internal Revenue Code 2704 (IRC 2704) impacting the valuation of privately-held, minority interests that are controlled by the same family.

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