Section 10.6 Selected Income Tax Issues With Respect to Family Limited Partnerships and Family Limited Liability Companies
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E. (§10.6) Selected Income Tax Issues With Respect to Family Limited Partnerships and Family Limited Liability Companies
The income taxation of partnerships is beyond the scope of this chapter. But in structuring FLPs and FLLCs, there are some income issues that should be reviewed by the estate planner.
The family partnership rules under I.R.C. § 704(e) are designed to ensure that the income of a partnership (for purposes of this chapter, it is assumed that an FLLC will be treated as a partnership for...
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