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Although the details are significant, the bottom line is that the proposed regulations would appear to eliminate almost all minority (lack of control) discounts for closely held entity interests, including active businesses owned by a family. To accomplish that, restrictions under the governing documents and even those under state law would be disregarded for valuation purposes.

Source: Treasury Issues Broad Proposed Section 2704 Regulations


If attacked, do you want to be Victor or Victim?
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David R. Duringer, JD, LL.M, is a concealed firearm instructor and tax lawyer specializing in business and estate planning; licensed to practice law in the states of California and Washington. He is managing shareholder at Protective Law Corporation, serving Southern California from its Laguna Hills (Orange County) headquarters and satellite offices in San Diego County (Coronado and Carlsbad).

© Protective Law Corporation as per date of publication captioned above. All rights reserved unless otherwise noted. Sharing encouraged with attribution and/or link to this page.



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