USPAP cited in IRS final regs on donations
The Internal Revenue Service (IRS) has issued final regs on valuing charitable donations that specifically cite the Uniform Standards of Professional Appraisal Practice (USPAP) of The Appraisal Foundation.
How the IRS Determines Reasonable Compensation and What You Should Do
In the most up-to-date commentary on reasonable compensation and the IRS, Mike Gregory, the original champion with the IRS on this issue, gives commentary on how to determine reasonable compensation for federal tax purposes. With fresh insight from developing his latest book, Business Valuations and the IRS, Five Books in One, Gregory will cover three IRS Job Aids including highlights of the Job Aid on Reasonable Compensation. He'll then critique each and offer valuable insights ...
Valuing an S-corporation? Ten books and articles you absolutely should read
View a list of essential reading for business appraisers preparing to value an S corporation, from valuation expert and former IRS territory manager, Michael Gregory.
Internal IRS memo unearthed re: S corp valuations
During a webinar, Michael Gregory (Michael Gregory Consulting LLC) discussed an internal IRS memo he recently obtained via a Freedom of Information Act (FOIA) request that has implications for valuing noncontrolling interests in S corps.
New Tax Legislation Consequences on U.S. Transfer Pricing and Intangibles
The Tax Cuts and Jobs Act of 2017 (the Act) brought sweeping changes to the international tax landscape, including the transfer pricing arena. Intangible property is at the core of many of these changes. Plus, the IRS is cracking down on this area.
Trial Court’s Stock Valuation Contravenes Agreement’s Buyout Provisions
In shareholder dispute over minority owner’s stock buyout, appeals court finds trial court’s sole reliance on five-year-old valuation and its rejection of appraiser’s recent valuation violates parties’ shareholder agreement and requires revaluation.
R. Kashmiry & Assocs. v. Ellis
In shareholder dispute over minority owner’s stock buyout, appeals court finds trial court’s sole reliance on five-year-old valuation and its rejection of appraiser’s recent valuation violates parties’ shareholder agreement and requires revaluation.
What You Need to Know About DLOMs and the IRS
With fresh insight from developing his recent book, Business Valuations and the IRS, Mike Gregory provides you with the highlights of what you need to know about discounts for lack of marketability (DLOM ) when providing a business valuation report for federal tax purposes. The DLOM is one of the most common adjustments by IRS valuers, so you need to know how to minimize the potential of your business valuation report being audited on this ...
Tax Court's Koons decision withstands appeal: DLOM ruling anchors valuation
The 11th Circuit recently affirmed a four-year-old Tax Court valuation of a revocable trust’s interest in a limited partnership. The linchpin in the valuation was the marketability discount.
Appraiser ducks penalty for undervaluation
A recent Tax Court case rejects an appraiser's valuation of an estate asset, and the undervaluation is enough to normally trigger penalties under IRC Section 6695A.
Michael Jackson estate valuation case features tainted image and tax affecting
BV experts take the stand in a high-stakes Tax Court case that pits the IRS against the estate of Michael Jackson.
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.
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.
IRS and Whitney Houston estate tangle over IP values
The IRS claims that the Whitney Houston estate underreported the value of intellectual property rights by $22.6 million.
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.
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.
Subsequent Transaction Too Remote to Allow for Reliable Valuation
In gift tax dispute involving decades-old transaction by a media magnate, Tax Court upholds IRS’s deficiency ruling and credits agency expert’s valuation of transferred stock based on a similar arm’s-length transaction occurring near the valuation date.
Redstone v. Commissioner
In gift tax dispute involving decades-old transaction by a media magnate, Tax Court upholds IRS’s deficiency ruling and credits agency expert’s valuation of transferred stock based on a similar arm’s-length transaction occurring near the valuation date.