This Treatise is a comprehensive analysis of the Code sections that provide estate tax relief for farms and other qualified family-owned businesses.
Estate Planning for Farms and Other Family-Owned Businesses - Bellatti
Chapter 1: Overview of Estate Tax Special Use Valuation
Chapter 2: Structuring Asset Ownership to Meet § 2032A Percentage Tests and Maximize § 2032A Value Reductions
Chapter 3: Planning to Meet the § 2032A Material Participation Requirement
Chapter 4: Planning to Meet the § 2032A Qualified Use Requirement
Chapter 5: Drafting Wills and Trusts to Qualify Under § 2032A
Chapter 6: The § 2032A(c) Additional Estate Tax (Recapture Tax) on Qualified Heirs
Chapter 7: Determining Availability and Advisability of § 2032A Election
Chapter 8: Generation-Skipping Transfer Tax Planning for the Family Farm
Chapter 9: Making the § 2032A Election on Form 706
Chapter 10: Overview of § 2057 Estate Tax Deduction for Qualified Family-Owned Business Interests
Chapter 11: Definition of a § 2057 Qualified Family-Owned Business Interest
Chapter 12: The § 2057 50 Percent of Adjusted Gross Estate Requirement
Chapter 13: The § 2057 Material Participation Requirement
Chapter 14: The § 2057(f) Recapture Tax on Qualified Heirs
Chapter 15: Estates Eligible to Elect Either or Both § 2032A and § 2057
Chapter 16: Making the § 2057 Election on Form 706
Appendix A. Section 2032A Interest Rates (1977–2016)
Appendix B. IRS Questionnaires and Checklists for Material Participation Audits
Appendix C. Section 2032A Drafting Checklist
Appendix D. Suggested Revisions to § 2032A Regulations on Successive Interest Rule
Appendix F. Form 706-A (Revised September 2004) and Instructions
Appendix I. Portions of GST Tax Final Regulations Referring to § 2032A
Appendix J. Maximizing Benefits of § 2032A With Tax Formulas: A Case Study
Appendix K. Basic Requirements During § 2032A Recapture Period
Appendix L. Suggestions for Regulations to Be Issued Under § 2032A(g)
Appendix M. Form 706 (Revised August 2002) and Instructions for §2032A Election
Appendix N. Attachment to Form 706, Schedule A-1 (Valuation Method)
Appendix O. Material Participation Affidavits (§ 2032A)
Appendix P. Completed Schedule A-1 for Regular §2032A Election
Appendix R. Completed Schedule R and Attachment
Appendix S. Committee Reports for 1984, 1986, 1988, and 1997 Amendments to § 2032A(d)(3)
Appendix T. Section 2032A Statute, Legislative History, and Regulations
Appendix U. Sample Paragraph for Trust Document Holding Title to Farm Real Estate Valued Under § 2032A
Appendix V. Committee Reports on § 2033A As Originally Enacted in the Taxpayer Relief Act of 1997
Appendix W. Section 2057 Statute
Appendix X. Senate Finance Committee Report and Conference Agreement on § 2033A Amendments (IRS Restructuring and Reform Act of 1998)
Appendix Y. Checklist and Forms to Make § 2057 Election, Schedule T, and Form 706 Separate Instructions for Schedule T
Appendix Z. Excerpts From HR Conf. Rep. 84, on the Economic Growth and Tax Relief Reconciliation Act of 2001, Pub. L. No. 16, 107th Cong., 1st Sess. (2001)
Appendix AA. Form 706-D (Revised October 2003) and Instructions