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Proposed Regulations for Partnership Interests Permits Estate, Income and Charitable Planning Opportunity

By Lawrence L. Bell

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.

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