Elaine Gagliardi on IRC Section 2704 Proposed Regulations Addressing Lapsing Rights and Restrictions (PDF)
The long-awaited I.R.C. Section 2704 proposed regulations were issued on August 4, 2016. If finalized, these regulations will have a significant effect on taxpayers' ability to apply valuation discounts to family controlled entities leading to the reduction in discounts currently available for gift and estate tax valuation purposes.
Elaine Gagliardi earned her J.D. from the University of Montana School of Law and her LL.M in taxation from New York University. She is a professor of law at the University of Montana School of Law, where she teaches courses in business organizations and estate planning. She also continues to practice in the estate planning area with George Law Offices, Missoula, Montana. She previously practiced with Perkins Coie in Seattle and with Day, Berry & Howard in Hartford, Connecticut. Elaine is past chairperson of the Business, Estates, Trust, Tax and Real Estate Section of the State Bar of Montana. Professor Gagliardi is the update author of How to Save Time & Taxes Handling Estates and the co-author of Modern Estate Planning (Second Edition) (with Professors J. Martin Burke & Michael Friel).
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