Estate and Gift Tax Valuation Discounts, GRAT Loopholes, Family Office Disclosure Exemptions

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Close Estate Tax Loopholes for the Wealthy

AKA “Wealth Protection Reform”


Which agency/agencies promulgated the regulation? *
Internal Revenue Service (IRS) / Securities and Exchange Commission (SEC) / Congress
Which title, parts, and/or sections of the Code of Federal Regulations (C.F.R.) should be rescinded? *
Rescind or amend regulatory provisions that permit valuation manipulation and exempt large private wealth managers from disclosure: 26 CFR § 20.2031-1 – Estate tax valuation rules that allow discounts for family control, marketability, and entity layering 17 CFR § 275.202(a)(11)(G)-1 – SEC exemption allowing family offices to avoid registration and public reporting as investment advisers
What is your name?
—OPTIONAL--
Is your proposed rescission a notice of proposed rulemaking, final rule, direct final rule, interim final rule, or interpretive rule? *
Notice of Proposed Rulemaking
What is the name of the regulation being rescinded, if applicable? *
Estate and Gift Tax Valuation Discounts, GRAT Loopholes, Family Office Disclosure Exemptions
Please provide a short summary of the justifications for the rescission. *
Rescind IRS and SEC exemptions that allow dynastic wealth holders to shield billions through valuation games, tax-free trusts, and unregulated private fund management.
Please insert the address of the agency. [NPRM, DFR, and IFR only]
Department of the Treasury Internal Revenue Service 1111 Constitution Avenue, NW Washington, D.C. 20224
Please insert the contact information for the agency. *
public_liaison@irs.gov
What is the background for the regulation being rescinded? *
Family offices and ultra-high-net-worth individuals use intentionally defective trusts, GRATs, and shell valuations to avoid billions in estate and gift taxes — far beyond what was envisioned by lawmakers.
Explain the reasons for the rescission. *
Closing these loopholes will: • Reduce intergenerational wealth hoarding • Rebalance the tax system toward fairness • Improve transparency in private capital markets
Describe the text of the relevant C.F.R. provisions as it will exist after the rescission. *
Estate and gift tax valuations shall reflect full fair market value without artificial discounts for family-controlled entities, restricted ownership structures, or lack of marketability. Family offices managing assets in excess of $100 million shall be required to register with the SEC as investment advisers and submit quarterly public disclosures of holdings, using a reporting framework comparable to Form 13F.
Please insert the name of the current agency head. *
Michael Faulkender
Please insert the title of the agency head. *
Acting Commissioner of Internal Revenue

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