Video

  • 8 minutes

(Non)-Aggregation of Business Interests and Impact on Valuation; Lifetime and Post-Mortem Planning

 
The potential impact of (non)-Aggregation of business interests can include the value of business interests influenced by size of interest relative to the entire business. Lifetime planning often takes advantage of minority discounts through fractionalizing interests. Discounts and premiums can impact post-death administration, i.e., in funding marital and charitable bequests. It is important, therefore, to recognize when family interests may be aggregated.

In this video our speaker, Christine Quigley, reviews non-aggregation of differently owned interests. She discusses lifetime and post-mortem planning to alter values. Ms. Quigley also reviews valuation challenges in funding post-death. Control premium can benefit a taxpayer to maximize value of a majority interest which qualifies for marital or charitable deduction. Contrast: P.L.R. 9403005, in which the IRS ruled that a control premium applied to decedent’s majority interest, even though the stock would be split and pass as two separate minority interests.

Christine Quigley is a partner in the Private Clients, Trusts and Estates group of Schiff Hardin LLP. She advises affluent individuals and families in wealth transfer planning, tax planning, estate and trust administration, and business succession planning. Mr. Quigley is the vice chair of the Business Investment Entities, Partnerships, LLCs and Corporations Committee of the American Bar Association’s Real Property, Trust and Estate Law Section and active in the Chicago Estate Planning Council.
Runtime: 7 minutes

Faculty

Christine Quigley

Christine Quigley

Schiff Hardin LLP

Agenda

Faculty

Christine Quigley

Christine Quigley

Schiff Hardin LLP

  • Partner in the Private Clients, Trusts and Estates group of Schiff Hardin LLP
  • Advises affluent individuals and families in wealth transfer planning, tax planning, estate and trust administration, and business succession planning
  • Chair of the Business Investment Entities, Partnerships, LLCs and Corporations Committee of the American Bar Association’s Real Property, Trust and Estate Law Section and active in the Chicago Estate Planning Council
  • Has been quoted in The Wall Street Journal and has written and lectured on a variety of topics that impact her clients, including carried interest planning, family partnerships, tax traps involved in closely held business transactions and business succession issues
  • Fellow of the American College of Trust and Estate Counsel
  • Has been named a 'Rising Star' by Illinois Super Lawyers magazine each year 2012–2016
  • J.D. degree, summa cum laude, with a certificate in tax law, Loyola University Chicago School of Law; B.A. degree, Dartmouth College
  • Can be contacted at 312-258-5522 or [email protected]

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