Comments started on proposed IRS regs regarding appraisers

BVWireIssue #268-2
January 15, 2025

tax valuations
estate and gift tax, estate valuation, estate & gift, federal taxation, internal revenue service (IRS)

Last week, we alerted you to proposed changes to its Circular 230 related to appraisers who do tax-related valuations. The revisions incorporate both USPAP and IVS standards into a new framework for determining appraiser disqualification. Under the proposed regs, all appraisals “should conform to the substance and principles” of USPAP or IVS.

Early comments: Comments have begun to be submitted, and one commenter says: “Incorporating both USPAP and IVS standards into the rule is a positive step towards ensuring high-quality appraisals.” But he expressed concern about “how inconsistencies between these two standards will be managed. Appraisers might find themselves in situations where the standards differ, and clearer guidance on which standard takes precedence would help avoid confusion and ensure compliance.”

We note that, back in 2018, The Appraisal Foundation (TAF) and the IVSC collaborated on a document, “A Bridge From USPAP to IVS,” that shows the differences between the two sets of standards and how appraisers familiar with USPAP can produce a valuation that is also compliant with IVS. Now may be a good time for a revision to this document.

Submit your comments: February 24 is the deadline for comments (electronic or written), and that is also the deadline for requests to speak at a public hearing, which will be March 6. Details on submitting comments and requests to speak are in the Federal Register document, which is available if you click here.

The valuation professional organizations (VPOs)—the AICPA, ASA, and NACVA—are reviewing the proposed regs for possible comment. BVR’s recently formed Leadership Council will be issuing some talking points for valuation practitioners to consider when submitting comments.

More details on the proposed regs are in the February issue of Business Valuation Update.

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