A family limited partnership (FLP) and a family limited liability company (FLLC) are two entity choices frequently used by estate planners to achieve federal estate tax (“estate tax”) savings. While many considerations impact the choice of a FLP versus a FLLC,5 one factor that probably escapes consideration by many practitioners is the impact of the passive activity loss (PAL) rules for Federal income tax (“income tax”) purposes on that choice.
Read entire article here.