The origin of Family Limited Partnerships (FLPs)

The original idea of Family Partnerships was essential to divide income among family members. With the recent reduction in marginal tax rates, the emphasis has shifted for exploiting the Family Partnership to reduce estate and gift tax.

One of the earliest, and most cited, Supreme Court cases is Lucas vs. Earl, 281 U.S. 111 (1930). The question presented to the court was whether Mr. Earl could effectively assign half of his compensation from practicing law between 1921 and 1922 by contract to his wife. The validity of the contract was not questioned. However, the Court held that the “fruits cannot be attributed to a different tree from that on which they grew.” This came to be known as the “Fruit of the Tree Doctrine” and has since found application in many areas.

Subsequent taxpayers attempted to use the partnership provisions in place of a bare contract to attempt to divert income to family members and others. If successful, this stratagem would not only reduce income and employment taxes, it would completely circumvent transfer taxes. With the decline in income tax rates, the principal focus in this area has become transfer tax avoidance.

flp

Family Limited Partnerships

  • The origin of Family Limited Partnerships (FLPs)

  • How Family Limited Partnerships (FLPs) work
  • Issues about asset protection
  • Family limited partnerships – Charging order protection
  • Future creditors and fraudulent transfers
  • Family Limited Partnership Review – Part1
  • Family Limited Partnership Review – Part2

  • Charging Order Protection
  • Uniform Limited Partnership Act – Section19
  • Family Limited Partnerships and the benefits of leverage
  • Family Limited Partnership (FLP) frequently asked questions
  • Family Limited Partnerships (FLPs) and creditor protection
  • Family Limited Partnerships (FLPs): keeping the family business in the family
  • The differences between Family Limited Partnerships and General Partnerships
  • Family Limited Partnerships and Family Limited Liability Companies work well
  • Family Limited Partnerships and IRS scrutiny
  • Building wealth with a Family Limited Partnership
  • Carefully planned Family Limited Partnerships can avoid IRS scrutiny
  • Court decision could affect Family Limited Partnerships
  • Family Limited Partnership structures
  • Defects in Family Limited Partnerships – Part One
  • Defects in Family Limited Partnerships – Part Two
  • Defects in Family Limited Partnerships – Part Three
  • Properly structuring a Family Limited Partnership (FLP) – Part One
  • Properly structuring a Family Limited Partnership – Part Two
  • Properly structuring a Family Limited Partnership – Part Three
  • Using Family Limited Partnerships for planning estates
  • Family Limited Partnerships (FLPs) and Family Limited Liability Companies (FLLCs)
  • What are Family Limited Partnerships (FLPs)?
  • Is a Family Limited Partnership (FLP) good estate planning?
  • Maintenance List for Family Limited Partnerships – Part One
  • Maintenance List for Family Limited Partnerships – Part Two
  • Maintenance List for Family Limited Partnerships -Part Three
  • Is a Family Limited Partnership (FLP) a good Estate Planning tool?
  • The attraction of Family Limited Partnerships (FLPs)
  • When Family Limited Partnerships are suitable
  • Family Limited Partnership Review
  • The uses and benefits of Family Limited Partnerships (FLPs)
  • More frequently asked questions about Family Limited Partnerships (FLPs) – Part One
  • More frequently asked questions about Family Limited Partnerships (FLPs) – Part Two
  • More frequently asekd questions about Family Limited Partnerships (FLPs) – Part Three
  • More frequently asked questions about Family Limited Partnerships (FLPs) – Part Four
  • More frequently asked questions about Family Limited Partnerships (FLPs) – Part Five
  • Family Limited Partnerships – an overview
  • Family Limited Partnerships (FLPs) attract IRS investigations
  • Family Limited Partnership “Do’s and Don’ts”
  • Family Limited Partnerships facing increased scrutiny by the IRS

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