Wealthy family, where father put most assets in an FLP. Father is the GP. Four children are LPs. FLP owns $10 million life insurance on GP, and $5 million on each of the LPs. GP has right to change beneficiary of all policies because he is GP. Other assets of FLP total $10 million, all liquid.
Will right to change beneficiary cause all assets of FLP to be included in estate of GP under Section 2036?