26 U.S. Code § 2704 - Treatment of certain lapsing rights and restrictions
The Secretary may by regulations apply this subsection to rights similar to voting and liquidation rights.
The Secretary may by regulations 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.
The term “control” has the meaning given such term by section 2701(b)(2).
The rule of section 2701(e)(3) shall apply for purposes of determining the interests held by any individual.
1996—Subsec. (c)(3). Pub. L. 104–188 substituted “section 2701(e)(3)” for “section 2701(e)(3)(A)”.
Amendment by Pub. L. 104–188 effective, except as otherwise expressly provided, as if included in the provision of the Revenue Reconciliation Act of 1990, Pub. L. 101–508, title XI, to which such amendment relates, see section 1702(i) of Pub. L. 104–188, set out as a note under section 38 of this title.
Written determinations for this section
These documents, sometimes referred to as "Private Letter Rulings", are taken from the IRS Written Determinations page; the IRS also publishes a fuller explanation of what they are and what they mean. The collection is updated (at our end) daily. It appears that the IRS updates their listing every Friday.
Note that the IRS often titles documents in a very plain-vanilla, duplicative way. Do not assume that identically-titled documents are the same, or that a later document supersedes another with the same title. That is unlikely to be the case.
Release dates appear exactly as we get them from the IRS. Some are clearly wrong, but we have made no attempt to correct them, as we have no way guess correctly in all cases, and do not wish to add to the confusion.
We truncate results at 20000 items. After that, you're on your own.
- More than One Class of Stock : 2004-02-13
- Certain Rights and Restrictions Disregarded : 2004-02-13
- Treatment of Lapsing Rights and Restrictions : 2004-02-13
- Gifts Indirectly Made : 2001-10-26
- Exceptions : 2001-10-26
- Right to Sell or Use Restrictions : 2001-10-26
- Closely Held Stock : 2001-10-26
- Certain Restrictions on Liquidations Disregarded : 2001-10-26
- Certain Restrictions on Liquidations Disregarded : 2000-12-08
- Certain Rights and Restrictions Disregarded : 2000-04-14
- Treatment of Lapsing Rights and Restrictions : 2000-04-14
- Certain Restrictions on Liquidations Disregarded : 1999-05-14
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