Key Tax Ruling From Ohio Supreme Court Concerning Pass-Through Entity
Ohio Supreme Court says tax provision imposing state income tax on capital gain realized by nonresident investor in pass-through entity violates taxpayer’s due process rights barring showing taxpayer’s activities are “unitary with” those of the business.
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.
A few nuggets from the NYSSCPA BV conference
BVWire provides a few key takeaways from the recent annual business valuation conference of the New York State Society of CPAs (NYSSCPA) in New York City.
No Place for DLOM and Tax Affecting in New York Fair Value Determination
In statutory fair value proceeding to enable buyout of minority interest in limited liability companies, New York court says prevailing expert opinion understates future income stream; court upward adjusts by eliminating DLOM and disallowing tax affecting ...
Key Tax Ruling From Ohio Supreme Court Concerning Pass-Through Entity
Ohio Supreme Court says tax provision imposing state income tax on capital gain realized by nonresident investor in pass-through entity violates taxpayer’s due process rights barring showing taxpayer’s activities are “unitary with” those of the business.
Corrigan v. Testa
Ohio Supreme Court says tax provision imposing state income tax on capital gain realized by nonresident investor in pass-through entity violates taxpayer’s due process rights barring showing taxpayer’s activities are “unitary with” those of the business.
Verghetta v. Lawlor
In statutory fair value proceeding to enable buyout of minority interest in limited liability companies, New York court says prevailing expert opinion understates future income stream; court upward adjusts by eliminating DLOM and disallowing tax affecting ...
Market says value of S Corps and C Corps differ, says Van Vleet
In Gallagher, the Tax Court took on a bulleted list of valuation techniques and “tough” spots, including adjustments to a DCF analysis and the reliability of the guideline public company method.
7th Circuit Affirms Tax Court; Gifts Were of Future Interests
This opinion is the 7th Circuit Court of Appeals’ ruling on appeal from the Tax Court opinion of Hackl v. Commissioner, 118 T.C. 279 (U.S. Tax Ct. 2002).
Hackl v. Commissioner (II)
Issue was whether restrictions on transfer in operating agreement meant that the gifted shares were "essentially without immediate value to the donees."
"Highly troubled" by Estate of Adams
I am highly troubled by several recent circumstances. You are familiar with Gross (BV Update has discussed it at length). It is clear to anyone with a modicum of financial background that ...