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Of late, much uncertainty has surrounded appraisals for estate and gift tax purposes. Though as financial experts watch judicial action and legislative inaction closely for signs of change and stability, the work of estate and gift appraisals continues with a singular constant: the Internal Revenue Service as reviewer.
In the Advanced Workshop on Estate & Gift Valuations for the IRS, expert Michael Gregory, a former territory manager with the IRS, joins BVR for an in-depth examination of what appraisers should know when performing a valuation for estate and gift tax purposes in light of IRS review. Join Gregory as he leads attendees through how the IRS views S-corp and FLP valuations, discounts for lack of marketability and control, and how appraisals work through the IRS structure, among other topics. For anyone preparing work that may be subject to IRS review, this intensive, four-hour workshop is not to be missed.
Program Agenda
Working with the IRS: Readers, Resolvers, and Issues
Organization of the IRS
Large Business and International (LB&I)
Small Business Self Employed (SBSE)
Who Controls Case - and Who is the Decision Maker at the IRS
Other Important Divisions
Issue Resolution
Actual Cases
Valuing Interests in S-Corp Valuations
1120S Corporations Background
Court Cases Summarized
Valuation Approaches Used
Personal Observations
Discounts for Lack of Marketability (DLOM) and the IRS
IRS Job Aid on Discount for Lack of Marketability at irs.gov Originally Prepared 9/2009 for IRS Valuers
August 2011 Developments
The Job Aide Public and Private
Comments on the Job Aid
Comments Since Entering Private Practice Regarding DLOM's
Family Limited Partnerships (FLP's)
Prerogatives of Control
Corporations
Partnerships
Family Limited Partnerships
Examples
Discussion
Learning Objectives
Learn how the structure and organization of the IRS can affect the review of your work
Learn how sub chapter S rules affect valuations for estate and gift purposes
Learn how to treat discounts for lack of marketability and control when preparing for the IRS
Learn what views the IRS holds on contentious appraisal methods and thinking, and how best to prepare for comments and review in these areas
Learn how to prepare and defend a sound estate & gift valuation for IRS consumption and review
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