Estate Planning for Owners of Closely Held Business Interests (Portfolio 809)


Louis Mezzullo

Consulting Partner


At a glance

I. Introduction
II. Transfer of Closely Held Business Interest
III. Payment of Estate Taxes
IV. Estate Planning for S Corporations
V. Estate Planning for Partnerships and LLCs Taxed as Partnerships


Bloomberg Tax Portfolio, Estate Planning for Owners of Closely Held Business Interests, No. 809, is designed as a guide to the lifetime and post-mortem estate planning techniques primarily applicable to the owners of interests in closely held businesses.

Detailed consideration is given to various kinds of buy-sell agreements, including cross-purchase and stock redemption agreements; the gift and estate tax rules governing the lifetime disposition of closely held business interests, with special emphasis on §§2701-2704; the use of recapitalizations, charitable bail-outs, and private annuities to accomplish retirement, gift, and estate planning goals; §§303 and 6166 “relief” provisions concerning the payment of estate tax where the estate consists in significant measure of an interest in a closely held business; the rules which apply to subchapter S corporations; and special considerations when using a limited liability company.

This Portfolio may be cited as Mezzullo, 809 T.M., Estate Planning for Owners of Closely Held Business Interests.

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