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Internal Revenue Bulletin:  2016-36 

September 6, 2016 


Table of Contents


These proposed regulations provide additional guidance under section 2704, which contains special rules for valuing interests in corporations and partnerships transferred within the family, for estate, gift and generation-skipping transfer (GST) tax purposes. The proposed regulations add a new section to address restrictions on the liquidation of an individual interest in a family controlled entity and the effect of small interests held by persons who are not members of the family. The effect of these revisions is to disregard restrictions that reduce the value of the interest for tax purposes, but do not reduce the value of the interest to the family-member recipient.

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