Guidance on Material Participation For Trusts, Estates May Emerge in Stages


Richard Dees said that although proposed rules under Tax Code Section 2704 dealing with valuation discounts have garnered significant interest, many estate planners are still unaware of them. Mr. Dees expressed concern that new regulations “may limit the availability of minority ownership and lack of marketability discounts for valuing equity in family-owned companies. In other words, they may revive the concept of family attribution under the pretext of limiting liquidation and other restrictions.”