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New Star Wars film blockbuster fuels celeb estate valuation issue

For Rogue One: A Star Wars Story, the late actor Peter Cushing was “digitally resurrected” and appears as the future Death Star commander. Some stars are now taking action, such as having themselves scanned, so they, too, can provide for their heirs when they’re in the hereafter and enhance the value of their right of publicity.

Valuation challenges posed by digital assets

Social media, audiobooks, music and video files, bitcoin, and other digital assets pose estate planning and valuation challenges, explains a new paper. A handy checklist is also provided.

IRS addresses some concerns of valuators at Sec. 2704 regs hearing

IRS and Treasury officials on the hearing panel felt compelled to make a few remarks in response to the strong concerns of valuation experts, attorneys, wealth planners, and family business owners who testified.

Cavallaro v. Commissioner (Cavallaro II)

Court of Appeals finds Tax Court held mistaken view of burden of proof and erred in declining to evaluate taxpayers’ multiple challenges to IRS’s expert valuation; on remand, Tax Court may consider new valuation evidence, appeals court says.

Court of Appeals Sides With Taxpayers on Right to Vet IRS Expert Valuation

Court of Appeals finds Tax Court held mistaken view of burden of proof and erred in declining to evaluate taxpayers’ multiple challenges to IRS’s expert valuation; on remand, Tax Court may consider new valuation evidence, appeals court says.

What appraisers need to know to prepare for IRC Section 2704

IRS inundated with comments on proposed IRC 2704 regs

Over the past week, over 100 new comments have been submitted to the IRS about the controversial proposed Section 2704 regs designed to rein in estate tax valuations. That brings the total comments to almost 200, but it's hoped that many more will come in before the due date of November 2.

Appraisers see spike in engagements due to proposed Section 2704 regs

At the ASA Advanced Business Valuation Conference last week in Boca Raton, Fla., valuation practitioners told us that they are seeing an increase in valuation engagements triggered by the proposed Section 2704 regulations. They expect the increased business to gain steam as the regs continue to sink in with attorneys, wealth planners, and clients.

Challenge to new Section 2704 regulations is shaping up

The accounting, valuation, and legal professions are hard at work to defeat the Treasury Department's proposed Section 274 regulations. The new regs would curtail, if not entirely eliminate, valuation discounts in family-controlled entities.

Act now to avert tough IRS crackdown on estate valuations

Well-crafted comments can change the course of the controversial proposed IRC Section 2704 regs designed to curb estate valuation discounts. There's a concern that, if these regs are finalized as proposed, the federal government will go after valuation discounts in other contexts. Comments are due by November 2, and there's a public hearing in Washington on December 1.

Tax Court revaluation means big-time savings for taxpayer

In an estate tax dispute that has lasted for over five years, the Tax Court recently revalued the decedent’s minority interest in an Oregon family business by order of the 9th Circuit Court of Appeals. The recalculation proved a boon to the taxpayer.

Dreaded IRS estate valuation discount regs released

The Treasury has released long-awaited proposed IRC Section 2704 regulations designed to curb estate valuation discounts. It appears that the proposed regulations eliminate almost all minority discounts for closely held entity interests, including operating businesses owned by a family. The proposed regs have triggered a strong response from the valuation community, legal profession, and others.

Manipulation of Valuation of Bequeathed Stock Sinks Charitable Contribution Claim

Tax Court says executor of estate in series of post-death measures changed the value and size of decedent’s stock donation and may not claim date-of-death value of assets not actually transferred to family foundation; court affirms estate tax deficiency.

Estate of Dieringer v. Commissioner

Tax Court says executor of estate in series of post-death measures changed the value and size of decedent’s stock donation and may not claim date-of-death value of assets not actually transferred to family foundation; court affirms estate tax deficiency.

A few highlights from the ASA Advanced Business Valuation Conference

IRS crackdown looms on valuation discounts for FLPs

TAM 200247001

The IRS denied discounts for potential income tax and lack of marketability in determining the value of the estate’s several IRAs. It noted that a section 691 (c) deduction is the appropriate remedy for the potential income tax consequences and makes a v ...