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Mission Critical in Divorce: 10 Key Insights in 50 Minutes-a Free AAML/BVR Virtual Divorce Conference Preview

Brought to you by the American Academy of Matrimonial Lawyers (AAML) and Business Valuation Resources (BVR), this free preview for the Virtual Divorce Conference brings together attorneys, valuation professionals, and industry experts in a one action-packed, 60-minute session. Get short compelling lessons that you need to know now. This year’s conference focuses on the topics most impacted by divorce, and anyone serving business owners involved in matrimonial dissolution can get access to this premium preview ...

Nelson v. Commissioner

In gift tax case, Tax Court finds donor transferred percentages in limited liability company rather than fixed dollar amounts based on language in transfer instruments; further, where transferred minority interests include elements of control, minority discount should be reduced, not eliminated.

Court Says Reduced Minority Discount Appropriate Where Minority Interest Has Elements of Control

In gift tax case, Tax Court finds donor transferred percentages in limited liability company rather than fixed dollar amounts based on language in transfer instruments; further, where transferred minority interests include elements of control, minority discount should be reduced, not eliminated.

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.

Office of Chief Counsel Internal Revenue Service Memorandum

IRS private letter ruling says that, under facts, gift tax valuation must consider merger that was being negotiated at the time the donor transferred company stock into a trust where the merger was only announced after the stock transfer and the announcement prompted an increase in stock value.

IRS Private Letter Ruling on Whether to Consider Pending Merger in Gift Tax Valuation

IRS private letter ruling says that, under facts, gift tax valuation must consider merger that was being negotiated at the time the donor transferred company stock into a trust where the merger was only announced after the stock transfer and the announcement prompted an increase in stock value.

Kress gift tax case signifies approval of tax affecting—at least in federal district court

One aspect that has valuators excited about the Kress v. United States gift tax case is that the federal court that ruled on the taxpayers’ challenge to the IRS’s gift tax assessment accepted valuations from both parties’ experts that applied a C corporation tax rate to value minority shares in an S corporation.

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 ...

Activist Tax Court takes on double inclusion problem in estate and gift tax case

In an estate and gift tax case, the U.S. Tax Court recently sided with the Internal Revenue Service when the court found the value of assets transferred from the decedent to a family limited partnership was includible in the value of the decedent’s gross estate. The real surprise lay in the court's decision to propose a new way of calculating the includible amount.

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.

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.

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.

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.

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