Most valuation discounts used today to cut gift and estate taxes could disappear by the end of the year. That’s how soon recently proposed Treasury regulations that dramatically curtail discounting could be adopted. Urging clients to consider transfers to family members while significant discounts remain available is thus a year-end tax-planning priority.

“It’s the biggest thing going on in my business right now,” says CPA Tony A. Rose, founding partner of Rose, Snyder & Jacobs LLP, an accounting firm in Encino, Calif. “If the client hasn’t used the full $5.45 million per person exemption from estate and gift tax, it would be smart to revisit making transfers. Clients who want to gift are better off doing it now than a year from now.”

The interest rates for intra-family dealings, i.e., the Applicable Federal Rate under Internal Revenue Code Section 1274(d) and the code Section 7520 rate, hit their 2016 lows in August, and that’s noteworthy because some discounting techniques provide additional tax savings when rates are low. Grantor retained annuity trusts (GRATs) and installment sales to intentionally defective grantor trusts, including sales involving regular promissory notes, self-canceling installment notes and private annuities, fall into this category, says estate planning attorney Steve Oshins, a partner at Oshins & Associates LLC in Las Vegas.

But don’t let the environment entice clients into gifting assets they need. “When you make a transfer, theoretically you’re not using that money anymore,” Rose tells advisors to remind clients.

Treasury is taking public comments on the proposed changes through November 2, followed by a hearing December 1. All but one proposal would take effect upon publication of final regulations, while the other proposed rule would be effective no sooner than 30 days afterward.

Unfortunately, “We really don’t have a good idea on the timing of the final regs,” says Mark Luscombe, principal analyst at Wolters Kluwer Tax & Accounting, an information company in Riverwoods, Ill. “The proposed regulations are arousing some controversy, so there could be a lot of comments the IRS might want to thoughtfully consider.”

Or not.

Get An Early Jump 

Impending changes to the due dates of certain business returns have been cheered by the American Institute of Certified Public Accountants, CPAs’ membership organization, even if some practitioners are skeptical about the purported benefits. Domestic partnership returns, including returns for limited liability companies that file as partnerships, are due March 15, 2017, versus April 15 in prior years. Returns for calendar-year C corporations have made the opposite switch; they’ll be due April 18, 2017, instead of in mid-March.

In theory, this allows a partnership to finish its return and distribute Schedule K-1, showing each partner’s share of the profits and other tax items, in time for individual and C corp partners to file in April.

It may work out that way for partnerships where all the accounting is done under the client’s roof, such as with an operating business or a family entity involving real-property rentals, says Rose. But he doesn’t see investment partnerships meeting the March 15 due date when, heck, many couldn’t make the old April deadline.

A chief concern is that “there is going to be a real timing crunch for accountants, especially in states that haven’t changed their laws to follow the federal changes, like Massachusetts,” says Michael Barbera, a CPA and principal of the accounting firm Edelstein & Company LLP in Boston. Bay State accountants face the prospect of returns for both their partnership and C corp clients falling due on March 15, the former at the federal level, the latter when they must meet state filing requirements. “That’s a lot of work in two and a half months,” Barbera sighs.

Wisconsin and Illinois tax pros face a similar situation as of this Labor Day writing, according to Wolters Kluwer analyst Timothy Bjur.

Accounting firms everywhere could be so jammed trying to meet the sped-up partnership deadline that clients who historically have filed early may not be able to, and more clients could require extensions, particularly if the accounting firm they use prepares a lot of partnership returns, Barbera says. “This is very big.”

Advisors can help by getting clients to help their accountants. Clients should begin gathering tax data now. Business owners should be talking with their accountant about ways to close the books fast once the year ends, Barbera says. “Do any testing for audits that you can prior to year-end, and get information to the accountant at the beginning of January, especially if the business files in multiple states—who’s working in what state, the sales in each state,” Barbera says.

The advice is similar for clients who file FinCEN Report 114—the Report of Foreign Bank and Financial Accounts, or FBAR. Now it is due with the client’s individual tax return in April, versus June 30 in prior years, adding to tax practitioners’ spring workload. “We’re reaching out to our clients who have foreign bank accounts to begin compiling the information,” Barbera says, adding that the FBAR filing can be extended along with the client’s individual return.

Improve Relationships Now

Tax-planning time is an opportunity for advisors to provide value to clients by quarterbacking their financial team.

Rose, the Encino CPA, says, “It is a really good idea for the financial advisor to get permission from clients to send a quarterly report to their accountants to make them aware of any meaningful transactions. Open communication between all the client’s advisors during a transaction is often the difference in making a transaction really impactful.”

Finally, make sure your clients are with the right accountant, advises John Wheeler, a senior financial consultant at Castle Wealth Advisors in Indianapolis. “If the client has developed a good working relationship with the accountant, then they’re doing tax planning. If they haven’t, then they’re not,” Wheeler says. “We’re encouraging clients to develop that relationship by asking the accountant questions, and if the accountant is hesitant in talking to them, we suggest they find somebody else.”