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Discounts Vs. Step-Up Basis: Tax Rate Arbitrage Gone Bad (Or Not As Good As Expected)?

The Journal of Passthrough Entities

In 2014 and going forward, income tax planning in estate planning will be parallel in importance to estate tax planning. For estate planners, planning for the step-up in basis (until that too is repealed) is a critical step. And in the partnership context, that step becomes critical. Typically, discounts for estate tax purposes reduce the potential step-up in basis and are therefore costly from an income tax perspective. That increased income tax burden will become apparent when a partner exits from the partnership.

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