For many years, company owners have used LLCs and limited partnerships to pass on businesses to their heirs. Passing on these business interests might also be accompanied with a transfer of marketable securities wherein the partnership keeps control but the gift overall reduces assets and therefore the tax burden. 

This practice is now under scrutiny from the IRS because securities can be appraised and receive a discount, which reduces the amount of the gift and the tax associated with the transaction. This gifting methodology, which allows for those who have exceeded the single or couple lifetime gift exemptions, has been used by wealthy individuals for many years.

It looks like new regulations may be coming down the pike as soon as September, stretching beyond securities. These new regulations might look to eliminate or reduce tax reductions that are linked to privately-owned companies, too.