In the context of a family business, we are sometimes presented with situations in which the business wishes to sell property to, or acquire property from, a family member or an affiliated business in which he is involved. The transferors are often surprised by the tax consequences of these transactions.

Assume that Taxpayer owns land

Many of us encounter family-owned corporations in which the founder’s children are engaged in the business to varying degrees.  They may even own shares in the corporation.  These situations present difficult estate and succession planning considerations for the family and the business.

Scenarios

It may be that two siblings actively participate in the business.  They