The tax games available for Family Limited Partnerships are about to be severely limited. FLP’s are often used for tax limiting purposes in estate planning and the transfer of business ownership.
On August 6, 2015, the Department of the Treasury issued Notice 2015-54 announcing its intent to issue new regulations addressing Family Partnership transactions or, more broadly, involving partnerships formed by related parties.The Notice indicates expansive new regulations intended to address situations in which Treasury believes partnership transactions among related parties can lead to inappropriate tax results.