The IRS has been more aggressive at arguing for reduced discounts used in family limited partnerships and other tax structures, and Congress has recently debated whether to eliminate fractional discounts for asset transfers among family members.

Laura Weintraub Beck, a principal in the private clients group of law firm Cummings & Lockwood LLC in Greenwich, Conn., said that estate planners are "keeping an ear to the ground" on what Congress might do to change the valuation of fractional interests because they often are used in planning for and eventually appear in the bigger, more complex estates of high net worth individuals.

 

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