If the value of an interest in a closely held business which is included in determining the gross estate of a decedent who was (at the date of his death) a citizen or resident of the United States exceeds 35 percent of the adjusted gross estate, the executor may elect to pay part or all of the tax imposed by section 2001 in 2 or more (but not ex...

Property owned, directly or indirectly, by or for a corporation, partnership, estate, or trust shall be considered as being owned proportionately by or for its shareholders, partners, or beneficiaries.

Section 6166 spells out several criteria that must be satisfied before the estate may be eligible to defer the payment of federal estate taxes: The decedent must have been a U.S. citizen or resident at death. An interest in a closely held business must be …

Internal Revenue Code § 6166. Extension of time for payment of estate tax where estate consists largely of interest in closely held business Current as of January 01, 2024 | Updated by FindLaw Staff

Regular underpayment interest rate (R%) interest accrues on unpaid deferred tax, late payments of deferred tax, or late payments of otherwise non-deductible interest computed on the tax deferred under section 6166. See Revenue Ruling 89-32. NOTE: The 6166 (a) election can be for a maximum deferral period of 14 years.

Property owned, directly or indirectly, by or for a corporation, partnership, estate, or trust shall be considered as being owned proportionately by or for its shareholders, partners, or beneficiaries.

26 U.S.C. 6166 - Extension of time for payment of estate tax where estate consists largely of interest in closely held business

2025年2月26日 · Learn how IRC 6166 allows eligible estates to defer federal estate tax payments, the requirements for qualification, and key administrative considerations. Estate taxes can create liquidity challenges, especially when much of an estate consists of illiquid assets like real estate or a family business.

2023年5月10日 · The answer may lie in section 6166 of the Internal Revenue Code (IRC), which in certain situations permits the executor of an estate to defer federal estate tax on a closely held business following an owner’s death. If the code’s requirements are met, the executor can elect to defer and spread payment of the estate tax attributable to the ...

Section 6166 is a useful tool when an estate is unable to pay estate or generation skipping taxes without selling assets at a loss. It is also useful when the estate is capable of earning a greater after-tax rate of return than it spends in interest for the deferral privilege.