|
|
Article: FLP transfers were bona fide.(family limited partnerships)
- Article from:
- The Tax Adviser
- Article date:
- July 1, 2004
- Author:
CopyrightCOPYRIGHT 2004 American Institute of CPA's. This material is published under license from the publisher through the Gale Group, Farmington Hills, Michigan. All inquiries regarding rights should be directed to the Gale Group. (Hide copyright information)
|
A's son E is the executor of her estate. In the years prior to her death, A transferred a large portion of her estate in a series of transactions to three entities:
1. A revocable living trust (T) created by A and administered by A and E as co-trustees.
2. A limited liability company (LLC), formed by A, E and his wife. T contributed $20,000 for a 50% interest. E and his wife each contributed $10,000 for 25% interests each.
3. A limited partnership (ALP) formed by T and the LLC. T contributed approximately $2.5 million in cash, oil and gas working interests and royalty interests, securities, notes and other assets, for a 99% pro-rata limited ...