Gift and Estate Tax Valuation Update

BVResearch Pro
Training Event Transcripts
October 19, 2021
Barry S. Sziklay, CPA, ABV, CFF, PFS
estate and gift taxation
case law analysis, transfer pricing, estate and gift tax, income tax, comparable profits method (CPM)

Summary

Join Barry Sziklay for important 2021 income and transfer tax valuation cases as well as the valuation aspects of the adequate disclosure regulations required to report a gift for federal transfer tax purposes and start the statute of limitations running. Internal Revenue Code (IRC) Chapter 14 valuations, Special Valuation Rules §§ 2701-2704, will be addressed in a summary fashion given the complexities of the rules required for a valuation to meet the requirements of Chapter 14. A very important transfer pricing (§482 Allocation of Income and Deductions Among Taxpayers) case involving billions of dollars of assessed taxes will be covered. In-depth coverage of Chapter 14 valuation and transfer pricing is beyond the scope of this presentation. Taxpayers in various courts including courts of appeal are currently contesting some of the issues covered in the presentation and handout materials, so practitioners are urged to keep that fact in mind as they consider the handout materials. Practitioners are, therefore, urged to shepardize any case upon which they intend to rely or consult competent legal counsel, in circumstances in which the current state of the law may be unsettled.
Gift and Estate Tax Valuation Update
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