Using an FLP or LLC? – Beware the step transaction doctrine
Abstract: Either a family limited partnership (FLP) or a limited liability company (LLC) can allow the transfer of a significant amount of wealth to the next generation at a discounted value for gift tax purposes. But if the IRS invokes the step transaction doctrine on the FLP or LLC, the tax outcome may be different from what was intended. This article discusses the doctrine and how to avoid running afoul of it.