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Estate Planning for Farms and Other Family-Owned Businesses

Estate Planning for Farms and Other Family-Owned Businesses

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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 (1977–2015)
    • 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