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.
Court Looks to Owner’s ‘Proportionate’ Share in Business to Quantify Appreciation in Value
In quantifying marital portion of appreciation of owner spouse’s separate property, trial court relies on owner’s “proportionate” share in company but also considers expert testimony as to third parties’ efforts and owner’s role in generating revenue; court rejects passive factor analysis.
Herbert v. Joubert
In quantifying marital portion of appreciation of owner spouse’s separate property, trial court relies on owner’s “proportionate” share in company but also considers expert testimony as to third parties’ efforts and owner’s role in generating revenue; court rejects passive factor analysis.
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.
Athlon Sports Communications, Inc. v. Duggan (II)
Court overrules precedent requiring exclusive use of Delaware block method to determine fair value in dissenting shareholder cases; trial courts may use other, more “modern” methods, including forward-looking DCF analysis, state high court says and remands for reevaluation of earlier ruling.
Delaware Block Method No Longer Mandatory in Tennessee Fair Value Proceedings
Court overrules precedent requiring exclusive use of Delaware block method to determine fair value in dissenting shareholder cases; trial courts may use other, more “modern” methods, including forward-looking DCF analysis, state high court says and remands for reevaluation of earlier ruling.
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.
Crocker v. Greater Colo. Anesthesia
Appeals court agrees with trial court that deal price does not reflect target’s fair value because price resulting from merger of medical entities compensated shareholders for agreeing to substantial future pay reduction and for making other concessions.
Deal Price Represents Unreliable Starting Point for Fair Value Calculation
Appeals court agrees with trial court that deal price does not reflect target’s fair value because price resulting from merger of medical entities compensated shareholders for agreeing to substantial future pay reduction and for making other concessions.
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 ...
City of Hialeah Emples. Ret. Sys. v. FEI Co.
Court rejects dissenting shareholder’s proxy challenge, finding board member statements about management projections are protected under applicable act’s safe harbor provision; also, court says financial advisor’s fairness opinion did not double count for risk in underlying DCF analysis.
Financial Advisor’s Fairness Opinion Not Materially Misleading
Court rejects dissenting shareholder’s proxy challenge, finding board member statements about management projections are protected under applicable act’s safe harbor provision; also, court says financial advisor’s fairness opinion did not double count for risk in underlying DCF analysis.
Appeals Court Upholds Insolvency Rulings in Transfer Liability Case
Appeals court upholds Tax Court’s transfer liability rulings; there was constructive fraud in that dividend payments to appellant were not compensation for services rendered but were part of a series of transfers leading to company’s insolvency.
Kardash v. Commissioner (III)
Appeals court upholds Tax Court’s transfer liability rulings; there was constructive fraud in that dividend payments to appellant were not compensation for services rendered but were part of a series of transfers leading to company’s insolvency.
Appeals Court Upholds Insolvency Rulings in Transfer Liability Case
Appeals court upholds Tax Court’s transfer liability rulings; there was constructive fraud in that dividend payments to appellant were not compensation for services rendered but were part of a series of transfers leading to company’s insolvency.
NAV Alone Fails to Capture Distributional Interest’s Fair Value
Appellate court affirms fair value determination of distributional interest in family farm based on multiprong valuation; company is not a holding company, and net asset valuation alone fails to capture fair value of dissociating members’ interest.
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.
Schewe v. Schewe Farms
Appellate court affirms fair value determination of distributional interest in family farm based on multiprong valuation; company is not a holding company, and net asset valuation alone fails to capture fair value of dissociating members’ interest.
NAV Alone Fails to Capture Distributional Interest’s Fair Value
Appellate court affirms fair value determination of distributional interest in family farm based on multiprong valuation; company is not a holding company, and net asset valuation alone fails to capture fair value of dissociating members’ interest.