“With its recent success in disputing the valuation of the reimbursement rights in economic benefit GSDs, the IRS is doubling down on its challenges to these arrangements.  Clients with existing EB GSDs should meet with their advisors now to review their options, putting together an action plan that can be implemented promptly, as needed, if and when there is a final decision on EB GSD valuation.  Clients considering new EB GSDs should contemplate the purpose of the arrangement and understand that no valuation discount may apply upon transfer of the GSD reimbursement.”

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