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Look, the mother and father have gifted the interests in the limited partnerships to children, not the assets. The actual limited partners do n’t have any control your assets. Therefore the value of this specific interest is gloomier than the need for the properties and assets. So a discount must be permitted on the price of the money. Many court decisions have upheld this as well IRS confirms. For estate, the discount is big, while for liquid assets (like cash) the discount is of course small. Generally IRS allows 40% discount, based on his or her nature of assets. Continuing the above example, the place that the assets transferred are $3 million, the financial lending exclusion is actually going to $1.8 billion dollars. This is $1.2 million more with the limited jv.
Balachandran, Kashi, et ‘s. “The Role of Transfer Pricing Schemes in Coordinated Supply Chains.” Journal of Accounting, auditing, and Finance 5.3 (2010): 375-380. Print.
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