From: Richard Joslin

From: Richard Joslin To: jeffrey E. <[email protected]> Subject: FW: FW: BNA Daily Tax RealTime Update - Aug 02, 2016 @ 11:40 AM Date: Wed, 03 Aug 2016 13:31:21 +0000 From: Richard Joslin Sent: Tuesday, August 02, 2016 7:12 PM To: Heather Gray c Subject: RN: RN: BNA Daily Tax RealTime Update - Aug 02, 2016 @ 11:40 AM From: Checkpoint [mailto Sent: Tuesday, August 02, 2016 12:43 PM To: Joslin, Richard Subject: BNA Daily Tax RealTime Update - Aug 02, 2016 @ 11:40 AM ,Daily Tax Realtime Today's Updates IRS Proposes Rules to Curb Estate Valuation Discounts Posted August OZ 2016, 12:27 P.M. ET By Allyson Versprille Proposed IRS rules on restrictions on estate valuation discounts add a new category of restrictions that would be disregarded in valuing transfers of family interests. The proposed regulations(REG-163113-02, RIN:1545-BB71), released today, are meant to close "a tax loophole that certain taxpayers have long used to understate the fair market value of their assets for estate and gift tax purposes," Mark Mazur, assistant secretary for tax policy at the Treasury Department, said in a blog.post. The rules address restrictions on the liquidation or redemption of interests in family-controlled entities. The added category of "disregarded restrictions" are restrictions that will be ignored if, after the transfer, the restriction will lapse or may be removed by the transferor or the transferor's family. A "disregarded restriction" as defined by the rules includes one that: "(a)limits the ability of the holder of the interest to liquidate the interest; (b) limits the liquidation proceeds to an amount that is less than a minimum value; (c) defers the payment of the liquidation proceeds for more than six months; or (d) permits the payment of the liquidation proceeds in any manner other than in cash or other property, other than certain notes," according to the Internal Revenue Service. Copyright 2016, The Bureau of National Affairs, Inc. EFTA00690906 Please do not reply to this message. It Is sent from an unattended mailbox. To ensure that e-mail from Checkpoint does not get filtered to your Spam or Junk Mail folder, please be sure to add the thomsonreuters domain to your Approved list OR add to your Contacts list in your e-mall client. If you no longer want to receive this e-mail, please click here and uncheck the option to e-mail RealTime(TM) updates. If your e-mail application does not support links to the Internet, log in to CHECKPOINT, select Options, and uncheck the option to receive RealTime(TM) updates. NOTICE: This e-mail is only intended for the person(s) to whom it is addressed and may contain confidential information. Unless stated to the contrary, any opinions or comments are personal to the writer and do not represent the official view of RSM US LLP or any of its affiliates (RSM US). If you have received this e-mail in error, please notify us immediately by reply e-mail and then delete this message from your system. Please do not copy it or use it for any purposes, or disclose its contents to any other person. Thank you for your cooperation. Any advice or information in the body of this email is subject to, and limited by, the terms in the applicable engagement letter or statement of work, including provisions regarding tax advice. RSM US is not responsible for, and no person should rely upon, any advice or information in the body of this email unless such advice or information relates to services contemplated by an engagement letter or statement of work in effect between such person and RSM US. EFTA00690907