FLPs:  Bad Facts Yield Bad Results!

FLPs: Bad Facts Yield Bad Results!

A brand new Tax Court Memo ruling gives us yet another glimpse into how the IRS defeats Family Limited Partnerships (FLPs). See Estate of Gore v. Commissioner, T.C. Memo. 2007-169 (6/27/07). After transferring funds to the FLP, the decedent did not execute any other...
FLPs:  Bad Facts Yield Bad Results!

Partial Termination of Qualified Plan (e-Book)

The point here is the Service has ruled when there is a 20% employee turnover rate (i.e., 20% of participating employees have had employment severed), there is a presumption that a partial termination of the plan has occurred. If this is true, then your qualified plan...