by Howard M. Zaritsky
In response to the President’s Executive Order of April 21, 2017, the Internal Revenue Service has issued Notice 2017-38, 2017, designating the Proposed Regulations under Section 2704 of the Internal Revenue Code as imposing an undue financial burden or adding undue complexity (or both).
The proposed regulations, issued on August 4, 2016, could dramatically expand the scope of Section 2704, particularly as it applies to transfers of limited partnership interests, non-managing membership interests, and non-voting stock. REG-163113-02, 81 Fed. Reg. 51413-02 (Aug. 4, 2016).