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Nearly 5% of estates now fall under HMRC’s inheritance tax rules (IHT)

BVWire—UK estimates that 28,000 estates fall into the inheritance tax (IHT) rules this year, an increase from 24,500 in 2015/2016.

Nelder discusses trends in fiscal business valuations for HMRC

As most British business valuators know, HMRC Shares and Assets Valuation (SAV) reviews (and sometimes questions) fiscal valuations. Staff at SAV have shrunk by about half over the years, but they still deal with many valuations (approximately 12,500 a year).

Valuators now have 90-day extension option for HRMC employment income or share scheme filings

Accountants and valuers file a significant number of extension requests for existing EMI agreements.

How IRS turmoil from the shutdown affects BV

The IRS is doing its best to recover from the government shutdown, but business valuation experts need to be aware of certain issues, according to Michael Gregory (Michael Gregory Consulting LLC), who gave an IRS update during a recent BVR webinar.

Top 10 observations on the Tax Cuts and Jobs Act (TCJA) from the perspective of business valuation professionals

BVR caught up with practitioners at the most recent AICPA Forensic & Valuation Services (FVS) Conference to collect some thought-provoking observations on how the Tax Cuts and Jobs Act (TCJA) is impacting valuations. Practitioners are still grappling with understanding the new law’s many provisions, so this list is certainly not exhaustive, and the thinking will continue to evolve.

2018 in review: The most important developments in the business valuation profession

The new tax law, lively debates, new guidance, a strong protest, and a simpler approach to estimating cost of capital were just some of the highlights in the business valuation profession during 2018.

IRS BV community is ‘fractured’

The IRS business valuation community is “very fractured,” leading to inconsistencies on audits, says former IRS manager Michael Gregory (Michael Gregory Consulting LLC).

Sit in on a real-world IRS audit

A former IRS manager will conduct a mock audit of an estate valuation matter during a special four-hour workshop on September 25.

What’s it like to be on the IRS audit hot seat?

Find out during a special four-hour workshop that pits a former IRS manager against a business valuer in a mock estate tax audit.

Top five business valuation tips from recent training webinars

As a busy business valuation professional, you may not always have the time to attend training events. We’ve compiled the top five tips from recent BVR webinars on the most timely and important topics in the profession.

Compromised Section 1031 appraisal sinks Exelon tax strategy for fossil fuel power plant sale

U.S. Tax Court Judge David Laro frequently has cautioned experts not to give in to hiring attorneys who want to shape the appraisal. Although federal and state discovery rules offer some protection for attorney-expert communication, there is a risk of exposure and with it a risk of damage to the expert’s work product and reputation. A recent Section 1031 case, which Judge Laro handled, illustrates what happens when the communication is discovered.

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.

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.

Delaware Supreme Court Judge Boos Chancery's Option Valuation Case Analysis

In reviewing one of the Delaware Court of Chancery's most noteworthy rulings from 2015, one judge on the state Supreme Court wrote a stinging critique of the trial court's analysis.

S Corp model now in Tax Court

At the recent NYSSCPA business valuation conference in New York City, Daniel Van Vleet (Stout Risius Ross) told the audience that the Van Vleet model (S corporation economic adjustment model) is being used for the first time in a pending U.S. Tax Court case. What’s more, both the IRS and the taxpayer are using it in this case, says Van Vleet.

NACVA's star-studded silver anniversary conference

Shannon Pratt, Roger Grabowski, Jim Hitchner, Nancy Fannon, and the Honorable Judge David Laro of the Tax Court are just a few of valuation thought leaders dubbed by NACVA as “industry titans” who gave presentations at the organization’s 25th anniversary conference in San Diego

Practice tips for valuation experts from tax court insiders

Judge Laro reminded experts to guard against domineering attorneys who insist on reviewing draft opinions and seek to nudge an expert into achieving a predetermined result. Valuation experts need to know the discovery rules (Rule 26 of the Federal Rules of Civil Procedure) rather than assume that all of the attorney-expert communication is protected.

BVR's Guide to Business Valuation Issues in Estate and Gift Tax

July 2010 978-1-935081-29-6 Hardcover, PDF (712 pages)

Linda Trugman

Business Valuation Resources, LLC

While estate and gift tax issues is still one of the top revenue producers for business appraisers, this area of the valuation industry continues to face new challenges. Issues such as tax-affecting S corporations, non-signing tax preparer penalties, and legal challenges from the IRS continue to complicate the estate and gift arena. Learn more >>

Business Valuation and Federal Taxes: Procedure, Law and Perspective, 2nd Edition

Hardcover (528 pages)

Judge David Laro, Shannon Pratt

John Wiley & Sons, Inc.

Combining the expert knowledge of Senior Judge David Laro and Shannon Pratt, Business Valuation and Federal Taxes, Second Edition presents the authors' decades of experience, with advice on everything practitioners need to know about the relationship between federal taxes and valuation, and specifically valuations relating to business interests. Learn more >>

How the IRS Values Non-Controlling Interests in S Corps with Job Aid Commentary by the Original IRS Champion

June 2015 Softcover (138 pages)

Michael Gregory

Birch Grove Publishing

The IRS internal white paper entitled “The IRS Valuation of Non-Controlling Interests in Business Entities Electing to be Treated as S Corporations for Federal Tax Purposes,  A Job Aid for IRS Valuation Professionals” dated October 29, 2014 has been reviewed, and Michael Gregory provides insights to help you the business appraiser respond to this commentary. Major elements of this document are presented and Michael Gregory offers his insights as to what this might mean for business valuers providing S Corp valuations for federal tax purposes. Learn more >>
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