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Pandemic Triggers Chances for Valuers in Exit Planning

Remarks from the AICPA ENGAGE conference on the timely opportunities for financial professionals in exit/succession planning. This article gives some basics on how valuation experts can leverage their experience into this type of consulting.

Estate planning opportunity amid depressed business values

Among the key takeaways from the recent ENGAGE 2020 conference sponsored by the AICPA was one of particular interest to business valuers.

Perfect Storm: COVID-19 and 2020 Election—Unexpected Windfall for E&G Tax Planning

Insights into the impacts on the estate and gift tax area and the opportunities it presents for business valuers.

Tax Court spurns IRS’ gift tax valuation theory and methodology

In a gift tax dispute, the U.S. Tax Court recently found for the taxpayer when it rejected the unusual reasoning and methodology the Internal Revenue Service’s trial expert proposed to keep low the discounts applicable to the nonvoting membership units in two limited liability companies (LLCs).

Grieve v. Commissioner

In gift tax dispute, Tax Court rejects IRS expert’s valuation of noncontrolling, nonmarketable interests in two LLCs; expert proposed valuation theory and method were intended to lower opposing experts’ minority and marketability discounts but lacked support in facts, case law, or among peers.

Tax Court Rejects IRS’ Value Analysis, Finding It Assumes Additional Actions Not ‘Reasonably Probable’

In gift tax dispute, Tax Court rejects IRS expert’s valuation of noncontrolling, nonmarketable interests in two LLCs; expert proposed valuation theory and method were intended to lower opposing experts’ minority and marketability discounts but lacked support in facts, case law, or among peers.

More than one valuation issue in Kress

Tax affecting is only one issue that makes the federal district court’s opinion in Kress a must-know for valuators, notwithstanding a recent reader comment that it’s doubtful the case would have received much attention had it not been for the tax-affecting angle.

Reader comment on Kress case coverage

Responding to the attention the Kress case has received (at BVR and elsewhere), Harry Fuhrman, financial analyst with the Internal Revenue Service, gave us the following comments.

Kress appeal still a possibility

As the valuation community ponders the reach of the recent Kress decision, many eyes are trained on the government’s next move.

Kress v. United States signifies approval of S corp tax affecting

In a gift tax case teeming with valuation issues, one notable aspect was that, in valuing the minority shares of an S corporation, both parties’ experts applied a C corporation tax rate to the company’s earnings and the court, without ado, accepted the practice.

Gift Tax Case Suggests Overall Acceptance of S Corp Tax Affecting

In gift tax case requiring valuation of minority shares in S corporation, district court accepts application, by all experts, of C corp-level tax rate to company’s earnings; court, with minor DLOM adjustment, credits valuations by taxpayers’ expert, noting his market approach is “the most sound.”

Kress v. United States

In gift tax case requiring valuation of minority shares in S corporation, district court accepts application, by all experts, of C corp-level tax rate to company’s earnings; court, with minor DLOM adjustment, credits valuations by taxpayers’ expert, noting his market approach is “the most sound.”

Tax Court’s Novel Theory Aims to Prevent ‘Double Inclusion’

Tax Court finds assets transferred into family limited partnership on behalf of incapacitated decedent shortly before death are includible in gross estate under IRC section 2036(a)(2); to avoid “double inclusion,” court states new rule limiting includible ...

Tax Court’s Novel Theory Aims to Prevent ‘Double Inclusion’

Tax Court finds assets transferred into family limited partnership on behalf of incapacitated decedent shortly before death are includible in gross estate under IRC section 2036(a)(2); to avoid “double inclusion,” court states new rule limiting includible ...

Estate of Powell v. Commissioner

Tax Court finds assets transferred into family limited partnership on behalf of incapacitated decedent shortly before death are includible in gross estate under IRC section 2036(a)(2); to avoid “double inclusion,” court states new rule limiting includible ...

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.

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.

Gift Tax Case Pivots on Key Assumption Informing Valuations

Taxpayer parents incurred gift tax liability when, based on improper valuations, they agreed to merge their S corp. with their sons’ S corp. and accepted an unduly low interest in the new company while sons received an unduly high interest, Tax Court says ...

Cavallaro v. Commissioner

Taxpayer parents incurred gift tax liability when, based on improper valuations, they agreed to merge their S corp. with their sons’ S corp. and accepted an unduly low interest in the new company while sons received an unduly high interest, Tax Court says ...

Estate of Kite v. Commissioner

At issue in this taxpayer action was whether the transfer of family partnership interests held by the decedent's lifetime revocable trust to her children in exchange for private annuity agreements was a disguised gift subject to gift tax.

The LLC as a Family Life Insurance Planning Tool

Schimmelbusch, Erik S. Oregon Estate Planning and Administration Section Newsletter , April 2001, Volume XVII, Number 2 This article presents the risks and benefits of using LLCs to hold life i ...

OBTAINING INFORMATION TO COMPLETE THE FORM 706

This in-depth article focuses on an estate planning attorney's responsibility to educate the personal representative of a decedent's estate of their obligation to file the Form 706, United States Esta ...

Protecting Your Valuation Expert and the Valuation Opinion

n Protecting Your Valuation Expert and the Valuation Opinion, Hood, Paul. Focus On Advanced Estate Planning Workshops . Planning for the Future, LLC. 19267 Slemmer Rd., Ste. 101, Covington, LA 7 ...

Federal and State Taxation of Limited Liability Companies, 1999 Edition

n FEDERAL AND STATE TAXATION OF LIMITED LIABILITY COMPANIES, 1999 Edition Cartano, David Panel Publishers, A Division of Aspen Publishers, Inc. , 1185 Avenue of the Americas, New York, NY 10036 ...

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