On August 4, 2016, Proposed Regulations under Section 2704 of
the Internal Revenue Code ("Proposed Regulations") were
published in the Federal Register that, when finalized, will
eliminate most valuation discounts in connection with the transfer
of interests in family controlled corporations, partnerships,
limited liability companies and other business entities. When
Congress enacted Section 2704, it was designed to attack several
perceived loopholes in the estate and gift tax laws. Section
2704(b)(4) authorizes the Treasury Department to issue regulations
to "provide that other restrictions shall be disregarded in
determining the value of the transfer of any interest in a
corporation or partnership to a member of the transferor's
family 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." By its terms, Section 2704 addresses (1)
