{"id":1605,"date":"2017-08-18T02:39:00","date_gmt":"2017-08-18T06:39:00","guid":{"rendered":"https:\/\/actec.matrixdev.net\/?post_type=capital-letter&p=1605"},"modified":"2024-01-07T19:36:59","modified_gmt":"2024-01-08T00:36:59","slug":"section-2704-proposed-regulations-under-dramatic-review","status":"publish","type":"capital-letter","link":"https:\/\/actec.matrixdev.net\/capital-letter\/section-2704-proposed-regulations-under-dramatic-review\/","title":{"rendered":"Section 2704 Proposed Regulations Under Dramatic Review"},"content":{"rendered":"\n

The White House orders an unprecedented review of burdensome tax regulations, and Treasury puts section 2704 proposed regulations on the menu.<\/strong><\/em>
<\/p>\n\n\n\n

Dear Readers Who Follow Washington Developments:<\/p>\n\n\n\n

The drama that defines Washington politics these days has implicated a closely-watched estate and gift tax guidance project in an unprecedented review.  The regulations on valuation discounts under section 2704, proposed a year ago, are one of eight regulation projects selected for reexamination in response to an Executive Order to identify unduly burdensome or complex regulations issued since the beginning of 2016.  The IRS asked for public comments, and many organizations, including ACTEC, vigorously responded.<\/p>\n\n\n\n

PROPOSED REGULATIONS UNDER SECTION 2704<\/strong><\/h2>\n\n\n\n

The\u00a0Proposed Regulations\u00a0were released on August 2, 2016, and published in the Federal Register on August 4.\u00a0 They were instantly controversial.\u00a0 They produced severe contention, not only between estate planning professionals and the IRS, but among estate planning professionals themselves, who have not reached a consensus on what effect the Proposed Regulations would have if finalized or what the Proposed Regulations even mean.\u00a0 The IRS reportedly received over 28,000 comments from members of the public, many very cursory and clich\u00e9d of course, but many deeper and broader and sometimes bitter.\u00a0 There were 36 speakers at the all-day public hearing on December 1.\u00a0 ACTEC submitted\u00a0Comments<\/a>\u00a0on October 27 that, in ACTEC\u2019s tradition, were thoughtful, professional, and evenhanded, and Stephanie Loomis-Price ably spoke on ACTEC\u2019s behalf at the hearing.<\/p>\n\n\n\n

This Capital Letter will describe the latest round of attention to the Proposed Regulations spurred by the Executive Order.  Unless unforeseen developments intervene, Capital Letter Number 41 will look in more depth at the Proposed Regulations themselves, particularly at the factors that created so much contention.  Capital Letter Number 42 will take a broader look at the current political and rhetorical climate and its implications for tax guidance.<\/p>\n\n\n\n

EXECUTIVE ORDER 13789<\/strong><\/h2>\n\n\n\n

Executive Order 13789<\/a> was issued on April 21, 2017, and published in the Federal Register on April 26.  It directed the Treasury Department to identify tax regulations issued on or after January 1, 2016, \u201cthat (i) impose an undue financial burden on United States taxpayers; (ii) add undue complexity to the Federal tax laws; or (iii) exceed the statutory authority of the Internal Revenue Service.\u201d  It directed that such regulations be identified in an interim report to the President within 60 days, or by June 20, 2017.<\/p>\n\n\n\n

NOTICE 2017-38<\/strong><\/h2>\n\n\n\n

Notice 2017-38<\/a>, 2017-30 I.R.B. 147<\/a>, was the initial response of Treasury and the IRS to the Executive Order.   It was issued on July 7, about two and a half weeks after its due date (although it may have been submitted to the President earlier).  It identified eight regulations, including the section 2704 Proposed Regulations, that it said \u201cmeet at least one of the first two criteria specified by \u2026 Executive Order 13789\u201d \u2013 that is, undue financial burden or undue complexity.  The Notice included this about the section 2704 Proposed Regulations:<\/p>\n\n\n\n

Commenters expressed concern that the proposed regulations would eliminate or restrict common discounts, such as minority discounts and discounts for lack of marketability, which would result in increased valuations and transfer tax liability that would increase financial burdens.  Commenters were also concerned that the proposed regulations would make valuations more difficult and that the proposed narrowing of existing regulatory exceptions was arbitrary and capricious.<\/p>\n\n\n\n

Understandably, the IRS did not concede that any of its regulations met the third criterion in the Executive Order because they \u201cexceed the statutory authority of the Internal Revenue Service.\u201d  But it would be at least noteworthy, if not surprising, that the IRS would admit that the Proposed Regulations impose \u201cundue\u201d financial burden or add \u201cundue\u201d complexity to the tax laws.  That would beg the question of why the IRS ever issued the Proposed Regulations in the first place.  But, to be fair, an IRS response that \u201cwe don\u2019t think anything we have done was undue\u201d would not really have captured the spirit of the Executive Order.  One way to read Notice 2017-38 is merely as an acknowledgment that if any<\/em> regulations potentially<\/em> create undue burdens or complexity, then the eight regulations identified in the Notice are the most likely<\/em> candidates.  Another way to read the Notice is that it simply measures undue burden by the intensity of the public reaction, which, in the case of the section 2704 Proposed Regulations, is reflected in the Notice\u2019s focus on what \u201ccommenters\u201d have said.<\/p>\n\n\n\n

The Notice asked for comments from the public by August 7.  ACTEC responded with a Letter<\/a> on August 1.<\/p>\n\n\n\n

THE MOST SERIOUS PROBLEMS WITH THE PROPOSED REGULATIONS<\/strong><\/h2>\n\n\n\n

Many features of the Proposed Regulations have been severely criticized, in professional meetings, in the press, in communications to Congress, and in the tsunami of over 28,000 public comments, including ACTEC\u2019s October 27, 2016, Comments.  ACTEC\u2019s August 1 Letter selected six of those troublesome features as the most conspicuous sources of the kind of undue burdens and complexity the Executive Order seems to be aimed at.<\/p>\n\n\n\n

1. Blurring the Standard of Transfer Tax Value<\/strong><\/h3>\n\n\n\n

The Proposed Regulations would make many changes affecting the tax treatment of transfers of interests in family-owned entities.  The most prominent, and perhaps the most controversial, is to add a new category of \u201cdisregarded restrictions\u201d that would be, as the name implies, disregarded under section 2704(b) in valuing such an interest for transfer tax purposes if the restriction lapses after the transfer or the transferor\u2019s family has the ability to remove it.  A restriction is a \u201cdisregarded restriction\u201d if it has the effect of limiting the ability of the holder of the interest to compel liquidation or redemption of the interest on no more than six months\u2019 notice for cash or property equal to at least what the proposed regulations call \u201cminimum value.\u201d  \u201cMinimum value\u201d is defined as the pro rata share of the net fair market value of the assets of the entity \u2013 that is, the fair market value of those assets reduced by the debts of the entity, multiplied by the share of the entity represented by that interest.<\/p>\n\n\n\n

If a \u201cdisregarded restriction\u201d encompasses anything<\/em> that restricts<\/em> or prevents an interest-holder\u2019s realization of \u201cminimum value\u201d on six months\u2019 notice, then the Proposed Regulations would require the valuation of that interest to assume that nothing<\/em> restricts or prevents such realization.  If everything<\/em> that prevented such realization were removed, then such realization would be permitted<\/em>.  The form of the entity, the management of the entity, the activities of the entity, the market or other economic environment in which the entity functioned \u2013 all would then be ignored.  The holder of an interest in the entity would then be treated as the direct owner of a pro rata share of the net fair market value of the entity, valued as such, with perhaps only a discount for the time value of money over a deferral period of six months.  The entity, in effect, would be disregarded.  And, assuming that the use of such entities to depress transfer tax values is what the Proposed Regulations must be aimed at, then the objectives of the IRS would be served.  Some described that element of the Proposed Regulations as the valuation of an interest in a family-owned entity as if<\/em> the holder could put<\/em> the interest to the entity (or other owners) for its \u201cminimum value\u201d \u2013 in other words a \u201cdeemed put.\u201d  And the \u201cdeemed put\u201d label caught on.<\/p>\n\n\n\n

At the public hearing on the Proposed Regulations on December 1, 2016, the first speaker, speaking on behalf of the AICPA, referred repeatedly to that \u201cput right\u201d (as did many other speakers).  After that first speaker\u2019s comments, ACTEC Fellow and Treasury Department attorney-adviser Cathy Hughes, a member of the government panel at the hearing, stated that \u201cto put your mind at rest, as we have said publicly before, there is no intended put right, and we will absolutely make that clear in the final regulations.\u201d  The view of Capital Letters, similarly, is that the Proposed Regulations do not impose a \u201cdeemed put right\u201d or \u201cminimum value\u201d as a standard of transfer tax value; there will be more about that in Capital Letter Number 41.  But the logic in the preceding paragraph, standing alone, is hard to refute.  And if an appraiser must assume that liquidation value is the standard and that liquidation can always occur within six months, no matter how impractical that is, then the result could only be a host of artificially inflated, sometimes grossly inflated, values.<\/p>\n\n\n\n

It is appropriate for Notice 2017-38 to state that \u201cCommenters expressed concern that the proposed regulations would eliminate or restrict common discounts, such as minority discounts and discounts for lack of marketability, which would result in increased valuations and transfer tax liability that would increase financial burdens.\u201d  Likewise, the Notice does well to state that \u201cCommenters were also concerned that the proposed regulations would make valuations more difficult and that the proposed narrowing of existing regulatory exceptions was arbitrary and capricious.\u201d  A new \u201cminimum value\u201d standard, supplanting the time-honored \u201cfair market value\u201d standard, would seriously disrupt valuations and baffle the appraisal community.  And, besides being \u201carbitrary and capricious,\u201d imposition of such a new standard of value would transgress the third criterion of Executive Order 13789, which Notice 2017-38 does not mention, by exceeding the statutory authority in section 2704(b)(4) only to \u201cprovide that other restrictions shall be disregarded \u2026 if such restriction has the effect of reducing the value of the transferred interest for purposes of this subtitle but does not ultimately reduce the value of such interest to the transferee.\u201d  Congress did not authorize regulations to disregard real<\/em> restrictions that really<\/em> reduce value and certainly did not authorize the affirmative prescription of new<\/em> substituted standards of value.<\/p>\n\n\n\n

Finally, while assurances about the intention to fix these problems in the final regulations are welcome, they have not alleviated the burdens of public frustration and fear these regulations, even in proposed form, have created.  For that reason, in light of Executive Order 13789 and the invitation in Notice 2017-38, ACTEC responded to the extraordinary uncertainties, frustrations, and fears with the extraordinary conclusion that there is no redemption for these Proposed Regulations other than to immediately withdraw them, and to re-propose them for further public scrutiny and comment only if and when these problems have been fixed.  Under the circumstances, it is hard to argue with that.<\/p>\n\n\n\n

2. Ignoring Nonfamily Members of an Entity<\/strong><\/h3>\n\n\n\n

In enacting section 2704(b), Congress chose to limit the disregarding of what it called \u201capplicable restrictions\u201d to restrictions that lapse after a transfer or can be removed by the transferor\u2019s family.  In prescribing \u201cother\u201d restrictions under section 2704(b)(4) in Proposed Reg. \u00a725.2704-3(b)(1), the IRS has taken the same prudent approach.  But this prudence is made illusory by the requirement in Proposed Reg. \u00a725.2704-3(b)(4) that interests of nonfamily members \u2013 not just \u201crestrictions,\u201d but interests of nonfamily members \u2013 must also be disregarded unless<\/p>\n\n\n\n

(A)  the interest has been held for at least three years;<\/p>\n\n\n\n

(B)  the interest constitutes at least 10 percent of the value of all equity interests;<\/p>\n\n\n\n

(C)  the interests of all nonfamily members in the aggregate constitute at least 20 percent of the value of all equity interests; and<\/p>\n\n\n\n

(D)  every<\/em> nonfamily member who holds an interest in the entity has, unbelievably, a \u201cput right\u201d for \u201cminimum value\u201d within six months \u2013 not the put right apparently meant to be hypothetical when used to define a \u201cdisregarded restriction,\u201d but a real<\/em> put right here.<\/p>\n\n\n\n

ACTEC Fellow Mickey Davis has perceptively noted that this combination of four traits is simply not observed in the real world of either family-owned or widely-held entities.  He likens the family member the Proposed Regulations would respect to the mythological gryphon (or griffin or griffon), which has the body and hind legs of a lion and the head and wings of an eagle.  Everyone knows what lions and eagles look like, but no one has ever seen a gryphon.  While the Preamble to the Proposed Regulations purports to target \u201cnominal\u201d interests held by nonfamily members like the interests given to the University of Texas in Kerr v. Commissioner<\/em>, 113 T.C. 449 (1999), aff\u2019d<\/em>, 292 F.3d 490 (5th Cir. 2002), the unrealistic constraints on respecting nonfamily owners mean that all nonfamily owners would be ignored in all or almost all cases.  ACTEC\u2019s August 1 Letter observes:<\/p>\n\n\n\n

To avoid the harsh application of the Proposed Regulations in settings where there is no reason for them to apply, a transferor, for example, would have to wait three years after forming an entity or welcoming nonfamily owners to the entity before transferring interests to members of the transferor\u2019s family. ACTEC views that restraint on transfer as an undue burden on the involvement of family members, especially younger-generation family members, in the stewardship and benefits of the family wealth. Moreover, the entity would have to give all of its nonfamily owners a redemption right that could favor nonfamily owners over the family that nurtured that wealth and created that entity, which ACTEC also regards as an undue burden on that family.<\/p>\n\n\n\n

3. Frightening Owners of Operating Businesses<\/strong><\/h3>\n\n\n\n

There is no reason for the Proposed Regulations to apply to family-owned operating<\/em> businesses.  In the case of an operating business, discounts from net asset values, or from values derived from comparisons with interests in comparable publicly-traded entities, are driven by the commercial and capital markets in which the business operates.  Lack of marketability is real.  Partially<\/em> liquidating a synergetic combination of real estate, equipment, inventory, working capital, personnel, management, governance, intellectual property, and business opportunities to accommodate a substantial cash buy-out is an absurd notion.  Artificial restrictions in governing documents add little or nothing.  Operating businesses thus have little or nothing to fear from limitations on such artificial restrictions, in light of the restrictions already inherent in economic realities.  That is especially true if the \u201cdeemed put\u201d alarm is an overreaction and those economic realities are not also disregarded (as Capital Letter Number 41 will discuss).<\/p>\n\n\n\n

Yet there is no question that owners of family operating businesses have been severely frightened by the harm that the Proposed Regulations supposedly threaten.  Indeed, as ACTEC\u2019s August 1 Letter states, \u201cthe outcry has evidently reached the ears of Congress, where, for example, bills to prevent the finalization of the Proposed Regulations have been titled the \u2018Protect Family Farms and Businesses Act\u2019 (H.R. 6100 and S. 3436 in the 114th Congress and H.R. 308 and S. 47 in the current 115th Congress).\u201d[1]<\/a><\/p>\n\n\n\n

If family-owned operating businesses really are not the target of the Proposed Regulations, and especially if they would suffer little or no impact under the Proposed Regulations anyway, then, as ACTEC\u2019s Letter goes on to say, \u201cthere will be nothing of substance to be lost \u2013 and very much calming of public outcry to be gained \u2013 by simply making an exception for family-owned operating businesses explicit.\u201d  Indeed, Cathy Hughes was reported as saying at the ABA Section of Taxation midyear meeting in Orlando on January 20, 2017, that such an explicit exception for businesses \u201cwould make most of the objections to these proposed regs go away.\u2026 We considered piggybacking on the 6166 definition of a closely held business\u201d but decided against it \u201cbecause 6166 is a mess.\u201d  (Allyson Versprille, \u201cFinal Estate Tax Rule May Add Closely Held Business Exclusion,\u201d Bloomberg BNA Daily Tax Report\u00ae<\/sup>, Jan. 24, 2017, at G-1.)<\/p>\n\n\n\n

One reason why section 6166, especially the patchwork of definitions and special rules in section 6166(b), is a \u201cmess\u201d is that it is so difficult to amend section 6166 in a thoughtful, intentional way.\u00a0 That is true in large part because congressional revenue estimating rules often treat a deferral of tax beyond the applicable \u201cbudget window\u201d \u2013 currently ten years \u2013 as a\u00a0loss<\/em>\u00a0of revenue, even though the deferred tax will eventually be paid with interest.\u00a0 But Treasury and the IRS should not feel so constrained in crafting an operating business exception for purposes of the Proposed Regulations.\u00a0 Proposed Reg. \u00a725.2704-3(b)(1)(iv) itself already has an \u201cactive trade or business\u201d exception from the payment-within-six-months element of the definition of a \u201cdisregarded restriction.\u201d\u00a0 And in the same year that the IRS published the Proposed Regulations, Treasury\u2019s \u201cGreenbook\u201d of tax legislative proposals included a proposed tax on unrealized appreciation at death, but contemplated an operating business exception, stating that \u201cpayment of tax on the appreciation of certain small family-owned and family-operated businesses would not be due until the business is sold or ceases to be family-owned and operated.\u201d\u00a0 Department of the Treasury, \u201cGeneral Explanations of the Administration\u2019s Fiscal Year 2017 Revenue Proposals\u201d at 156 (Feb. 9, 2016).<\/p>\n\n\n\n

Of course Treasury and the IRS will be concerned about an explicit exception that could be abused, for example by stuffing investment assets into an operating business or by otherwise structuring an investment entity to fit within whatever technical definition of an \u201coperating\u201d business is crafted.  For that reason, the relief for operating businesses might not be an explicit exception, but could perhaps be something like a series of sharply focused Examples with typical operating business fact patterns, which could be just as reassuring to everyone but those seeking to find loopholes for investment entities.  And if the Proposed Regulations are withdrawn in the meantime, all taxpayers and their advisers would be reassured that they will not be finalized until the proposed relief has been subjected to another round of public scrutiny and comment.<\/p>\n\n\n\n

4. Burdening Donees or Legatees Who Never Had Control<\/strong><\/h3>\n\n\n\n

The Proposed Regulations appear to apply to any family member who transfers a non-controlling interest in a family-owned entity, even if the family member never had control and never avoided the transfer tax the Proposed Regulations are presumably designed to protect.  Suppose, for example, that Founder creates Entity with restrictions on transfers and gives or bequeaths a one-fourth interest in Entity to each of Founder\u2019s four Children.  Presumably, whatever final rules emerge from the Proposed Regulations would apply to those transfers if they occur after the Proposed Regulations take effect.  If, later, one Child gives or bequeaths a one-twelfth interest in Entity to each of three Grandchildren (Child\u2019s children), or even gives or bequeaths the one-fourth interest to a single Grandchild, there seems to be no good reason to apply the Proposed Regulations at the Entity level to those transfers.  (They might still apply at the level of any additional entities or arrangements Child creates, such as entities to hold the one-fourth interest in Entity that Child received.)  Child should likewise be exempt from the Proposed Regulations if the transfers from Founder occurred in the past, before the Proposed Regulations had become final.<\/p>\n\n\n\n

Besides the obvious considerations of fairness that should reject the taxation of Child on something Child never owned, a \u201cone and done\u201d rule among generations would generally limit the application of the Proposed Regulations to the temporary<\/em> artificial restriction contemplated by section 2704(b)(4) that \u201creduc[es] the value of the transferred interest for purposes of this subtitle but does not ultimately reduce the value of such interest to the transferee.\u201d<\/p>\n\n\n\n

Again it might be necessary for such a modification of the Proposed Regulations to include special rules, such as for a case where more than one family member, not just a single \u201cFounder,\u201d maybe even family members in different generations, have joined together to create an entity and create artificial restrictions on transfers of interests in that entity.  But permitting the Proposed Regulations to impose a higher tax burden on someone who never had control seems to be an incontestable case of imposing an \u201cundue\u201d burden.<\/p>\n\n\n\n

5. Creating a Harsh Three-Year Rule<\/strong><\/h3>\n\n\n\n

The guidance project that produced the Proposed Regulations was described in the most recent Treasury-IRS Priority Guidance Plan<\/a> as \u201cRegulations under \u00a72704 regarding restrictions on the liquidation of an interest in certain corporations and partnerships\u201d \u2013 in other words, focused on section 2704(b).  In a surprise proposed amendment of the current regulations under section 2704(a), the Proposed Regulations would impose a claw-back rule if a transferor who divests control of an entity in a transfer now exempt under those current regulations dies within three years of that exempt transfer.  The August 1 ACTEC Letter points out that, as a result, \u201cany transferor who complies with all the known rules under section 2704 would still have the unfair burden of anxiety that the rules might retroactively change if the transferor dies within three years, no matter how unexpected that death is or how unrelated the transfer was to the timing of the transferor\u2019s death.\u201d  The unfairness of that result and the common sense of substituting a proven regulatory mortality test like that in the section 7520 regulations (which ACTEC recommended) are obvious.<\/p>\n\n\n\n

6. Bifurcating the Effective Date<\/strong><\/h3>\n\n\n\n

The new \u201cdisregarded restriction\u201d rules in Proposed Reg. \u00a725.2704-3 would not take effect until 30 days after the date the regulations are published as final regulations in the Federal Register.  That is the general rule of the Administrative Procedure Act (5 U.S.C. \u00a7553(d)) applicable to \u201csubstantive\u201d regulations.  The surprise amendments to the section 2704(a) regulations, and other amendments that update the types of covered entities, would take effect when they are finalized, without a 30-day deferral.  ACTEC has proposed using the 30-day deferral for everything in the Proposed Regulations, to eliminate the need to keep track of two separate sets of rules and to avoid litigation over what should have been viewed as \u201csubstantive.\u201d<\/p>\n\n\n\n

Section 2704 was enacted on November 5, 1990.  That is 321 months ago.  Can another month really matter?<\/p>\n\n\n\n

SOMETHING TO LOOK FORWARD TO<\/strong><\/h2>\n\n\n\n

Executive Order 13789 also directed the Treasury Department to \u201cprepare and submit a report to the President that recommends specific actions to mitigate the burden imposed by the regulations identified in the interim report.\u201d  It directed that this second report be submitted within 150 days of the Executive Order, or by September 18, 2017.<\/p>\n\n\n\n

Many critics of the Proposed Regulations have called for \u2013 or at least hoped for \u2013 some formal announcement from the IRS that it has heard the cries for relief and will ensure that the final regulations will provide it, perhaps addressing the issues raised in ACTEC\u2019s October 27, 2016, Comments (the most serious of which are recapitulated in ACTEC\u2019s August 1 Letter and in this Capital Letter).  So far those pleas have not been answered.<\/p>\n\n\n\n

But the Executive Order does ask for a report by September 18.  That may be interesting.<\/p>\n\n\n\n

\n\n\n\n

[1] Mirroring those bills, section 115 of the Fiscal Year 2018 appropriations bill reported out of the House Appropriations Committee on June 29, 2017, provides:  \u201cNone of the funds made available by this Act may be used to finalize, implement, or enforce amendments to Treasury Regulations proposed in the Notice of Proposed Rulemaking in the Federal Register on August 4, 2016 (81 Fed. Reg. 51413) (relating to restrictions on liquidation of an interest with respect to estate, gift, and generation-skipping transfer taxes under section 2704 of the Internal Revenue Code of 1986), or any substantially similar amendments to such regulations.\u201d<\/p>\n\n\n\n

Ronald D. Aucutt<\/p>\n\n\n\n

\u00a9 Copyright 2017 by Ronald D. Aucutt.  All rights reserved.<\/p>\n","protected":false},"excerpt":{"rendered":"

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