FLPs are effective legacy planning tools for families seeking to consolidate their assets and investments, engage and educate multiple generations in legacy management, and plan for business succession. If established solely for tax purposes and/or improperly formed and administered, an FLP’s creation typically will result in IRS scrutiny and challenge.
Family limited partnerships
Recent cases involving the transfer tax consequences of family entities like family limited partnerships (“FLPs”) and limited liability companies (“FLLCs”) emphasize that the success of family entities for legacy management requires careful planning in the entity’s creation and subsequent administration, including: (1) establishing evidence of non-tax motives, (2) complying with entity formalities, (3) prioritizing business…
Family limited partnerships (“FLPs”) and limited liability companies (“LLCs”, collectively, “FLPs/LLCs”) are often used for legacy management. The failure to have a legitimate nontax reason for establishing the FLP/LLC or to adhere to the formalities of managing the FLP/LLC, however, can cause inclusion of the underlying assets in the owner’s estate despite planning for a…
Thursday, November 19, 2015WRM#15-43 The WRMarketplace is created exclusively for AALU Members by the AALU staff and Greenberg Traurig, one of the nation’s leading tax and wealth management law firms. The WRMarketplace provides deep insight into trends and events impacting the use of life insurance products, including key take-aways, for AALU members, clients and advisors....
Thursday, June 25, 2015WRM#15-23 The WRMarketplace is created exclusively for AALU Members by the AALU staff and Greenberg Traurig, one of the nation’s leading tax and wealth management law firms. The WRMarketplace provides deep insight into trends and events impacting the use of life insurance products, including key take-aways, for AALU members, clients and advisors.…