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Business Succession Planning: The Debenture Solution

Daniel L. Gottfried

The IRS has recently attacked family limited partnerships (FLPs) with a vigor that the courts have followed. In turn, skepticism of succession planning for closely held corporations (CHCs) has grown. Thus, it has become important to look into new methods for transferring the value of an FLP or CHC from the founding generation to the beneficiaries in a tax-preferred manner. This course explores the debenture solution, an innovative technique of using debt instruments in lieu of equity in order to fulfill these objectives.

Topics covered include:

  • Code Sec. 2036: The Problem
  • Overview of The Debenture Solution
  • Analysis: Funding the Debentures—Tax Law
  • Pricing the Debentures
  • The Debt/Equity Problem
Course Details
Price:  $36.00
Field of Study:  Taxes
Prerequisites:  Basic understanding of succession planning
Level:  Intermediate
CTEC course number:  1075-CE-4182
Course was last updated on:  03/13/07
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Library:
Wealth Management

Technical Requirements:
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Credit Available For: Units
CPE 3 CPE
QAS 3 CPE
Enrolled Agent (Accepted by the IRS) 3 CPE
CTEC Federal 3 CE

Note: Recommended CPE credit is based on a 50-minute hour. Participants earning credits for states that require self-study to be based on a 100-minute hour will receive half the recommended CPE credits for successful completion of this course.

Since Continuing Professional Education requirements vary from state to state and are subject to change without notice, please contact your state board of accountancy for information on your CPE requirements and the applicability of this course to meet those specifications.

CCH has been approved by the California Tax Education Council to offer courses that provide federal and state credit towards the annual "continuing education" requirement imposed by the State of California. A listing of additional requirements to register as a tax preparer may be obtained by contacting CTEC at P.O. Box 2890, Sacramento, CA, 95812-2890, toll-free by phone at (877) 850-2832, or on the Internet at www.ctec.org.

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