Now that the IRS hearing on the Section 2704 proposed regs is history (see coverage here), everyone is waiting to see what happens next. We do know, based on IRS remarks at the hearing, that the final regs will not include an “implied put right” and will make it clear that the three-year rule will not be retroactive. It remains to be seen, however, how the IRS will respond to comments about other issues, such as how the regs redefine long-accepted definitions of fair market value, marketability, and control.
The main VPOs—the AICPA, ASA, and NACVA—all sent representatives to testify. NACVA had the strongest showing, with three speakers taking the podium on its behalf: Peter Agrapides (Western Valuation Advisors), Robert J. Grossman (Grossman Yanak & Ford LLP), and Mark Hanson (Schenck SC). NACVA also did a post-hearing video that you can watch if you click here. You’ll also find links to NACVA’s testimony and a transcript of the entire hearing.
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