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Proposed Partnership Regulations Create Estate and Charitable Tax Planning Opportunity
The New Year and the New Administration has areas of taxation estate planning and philanthropy on the front burner. No one is sure what will be happening with the minority discounts regulations of §2504 in turmoil and proposed guidance of the modification of charities partnership interest and unrelated business taxable income (UBTI). By integrating a number of tried and tested tools, we may create a platform for substantial savings.
The idea is the Charitable Family Limited Partnership (CFLP), which is a charitable giving vehicle that provides a substantial gift to charity, produces income tax savings for the donor, transfers significant wealth to the donor's descendants and allows a means for the donor's family to retain control over the transferred assets.
The basic structure of the CFLP is that senior members, usually parents, contribute appreciated assets to a limited partnership in exchange for general and limited partnership interests. The general partners, also usually the parents, manage the affairs of the partnership and typically receive a reasonable management fee for their services. (If this fee is unreasonable, the base of this planning option perishes.) The limited partners do not participate in the CFLP's management. As general partners, the parents retain control over the property transferred to the partnership. In addition, they control the entity or person selected as investment adviser, so they determine the partnership's investments and when and if any distributions will be made out of the partnership.
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