BVU News and Trends April 2020
A monthly roundup of key developments of interest to business valuation experts.
IRS update on how to file carryback refund applications
In a recent ABA webinar including IRS representatives, new practical information related to the carryback provisions in the recently passed CARES Act emerged.
IRS discusses tax implications of COVID-19 legislation
In an excellent ABA webinar that summarized and analyzed the COVID-19-related legislation Congress passed to alleviate the economic harm on businesses and persons, IRS Chief Counsel Michael Desmond spoke to some of the efforts the agency is making to achieve implementation.
The IRS to BVers: We want you!
No, not for an audit—the IRS is looking for experienced business appraisers to fill six open positions across the U.S.
Tales From the Trenches: How Recent Challenges with the IRS Impact Your Valuation
With a special focus on the recent Aaron U. Jones (USTC TCM 2019-101) case regarding tax affecting an S corp and a partnership, this workshop is the best way to get IRS insights short of going into litigation. Get real insights on how to avoid and what to do if working with the IRS on business valuation issues at all levels. Join Mike Gregory as he dives into conflict resolution (with assistance from the Collaboration ...
Landmark Jones case featured in upcoming workshop
“Read the Jones case,” an IRS official said when asked about the position the IRS is taking on tax affecting pass-through entities.
IRS ruling on subsequent events and valuation
In a private letter ruling, the IRS says that a pending merger is to be considered in valuing a company’s stock for gift tax purposes.
BVU News and Trends May 2019
A monthly roundup of key developments of interest to business valuation experts.
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.
BVU News and Trends November 2018
A monthly roundup of key developments of interest to business valuation experts.
Testing the S Corp Value Premium for Realism and Reasonableness
Not long ago, we attended the author’s session at a NACVA conference where she presented on this topic. We asked her for this article, which has some key takeaways from that session as well as from a longer paper she wrote.
BVU News and Trends October 2018
A monthly roundup of key developments of interest to business valuation experts.
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.
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 ...
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.
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.