Special Valuation Rules, "Estate Freezes" With Chapter 14: Code Secs. 2701-2704 (Currently Unavailable)

Author: Steven G. Siegel

Chapter 14 of the IRC provides special valuation rules limiting taxpayers’ ability to transfer appreciating property to family members while retaining some interest in or control over the property. Code Secs 2701-2704 cover these transactions, called "estate freezes," and impose an alternative valuation regime in which the value of the interests retained by the transferor are disregarded, resulting in an overvaluation of the transferor's gift for gift tax purposes. Exceptions allow some estate freezes to remain a possibility through use of trusts and other techniques, but the rules are complex. This on-demand course, Special Valuation Rules, ‘Estate Freezes’ with Chapter 14: Code Secs. 2701-2704, covers the special valuation rules on estate freezes and identifies restrictions placed on retained interests under Code Secs. 2701-2704.

Publication Date: March 2015

Designed For
Practitioners assisting clients in federal estate and gift taxes

Topics Covered

• Special valuation rules
• Estate freeze
• Code sections: 2701, 2702, 2703, 2704
• GRAT, GRUT, and QPRT
• Estate and gift tax

Learning Objectives

• Describe the special valuation rules designed to limit the ability of taxpayers to transfer appreciating property to their family members
• Identify planning opportunities to discuss with clients
• Recognize how to answer client questions on estate planning issues

Level
Intermediate

Instructional Method
Self-Study

NASBA Field of Study
Taxes (2 hours)

Program Prerequisites
Basic knowledge of federal estate and gift taxes.

Advance Preparation
None