Since last year, the taxmen have fired off a volley of advisory letters and audits asserting that Section 2703 of the tax code, passed in 1990, gives them broad power to disregard the existence of "abusive" limited partnerships for valuation purposes.

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At the time of nationalisation the government said that any subsequent valuation for compensation purposes should be based on the assumption that Northern Rock had not been a going concern.

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This bill would require consistent valuation for transfer and income tax purposes, modify the rules on valuation discounts, and require 10-year minimum term for Grantor Retained Annuity Trusts (GRATS).

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Unless people were getting fancy with valuation for estate tax purposes or the value of the underlying property skyrocketed in a very short period, you would expect that the transaction would be close to a wash for federal income tax purposes.

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