Tag Archives: IRC § 2036

The IRC § 2036 Trap in Planning With FLPs & Grantor Trusts

Posted on March 15, 2010 by David L. Silverman, J.D., LL.M. (Taxation)

Printer-friendly PDF Memorandum:  The IRC § 2036 Trap in Planning With FLPs & Grantor Trusts.wpd The IRS has advanced many theories to challenge the gift and estate tax savings occasioned by the use of family entities and grantor trusts in … Continue reading →

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Anticipating IRS Challenges to FLPs and FLLCs

Posted on March 15, 2010 by David L. Silverman, J.D., LL.M. (Taxation)

Possessed of favorable tax attributes and tremendous flexibility, family limited partnerships (FLPs) and family limited liability companies (FLLCs) have proliferated over the past decade and have become an integral part of many estate plans. They can be used to manage a family business, to implement a plan of family succession and can even serve as extremely effective testamentary instruments. Recognized as separate legal entities, FLPs and FLLCs also accomplish formidable asset protection objectives. Continue reading →

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