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Business Ownership Internal Revenue Service Fair Market Value

Husch Blackwell LLP

Unanimous Supreme Court Determines Company-Owned Life Insurance Increases Fair Market Value

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On June 6, 2024, the Supreme Court held 9-to-0 in Connelly v. United States that company-owned life insurance increases the company’s fair market value for estate tax purposes, and the company’s obligation to redeem a...more

Warner Norcross + Judd

Connelly v. United States Decision Affects Life Insurance for Closely Held Business Owners

Warner Norcross + Judd on

On June 6, 2024, the United States Supreme Court issued its opinion regarding Connelly, as Executor of the Estate of Connelly v. United States. This final decision will directly impact all closely held business owners that...more

Perkins Coie

Supreme Court Clarifies Estate Tax Consequences for Closely Held Company

Perkins Coie on

The Supreme Court of the United States issued an important ruling on June 6, 2024, clarifying the federal tax consequences of certain succession plans for closely held businesses. The Court held in Connelly v. United States,...more

Burns & Levinson LLP

Client Advisory: Valuing Closely-Held Stock for Estate Tax Purposes | Connelly v. U.S.

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Connelly v. United States involved determining the fair market value of a closely-held corporation for purposes of estate taxation. A corporation, owned by two brothers, was obligated to buy back the shares of the first to...more

DarrowEverett LLP

Buy, Sell, Pay Taxes: SCOTUS Decision Places Its Own Premium on Buy-Sell Insurance

DarrowEverett LLP on

All U.S. closely held businesses just received a warning from the highest court in the land that they should review their succession plans (or else risk a higher tax bill for the estates of their owners). On June 6, 2024, the...more

Rivkin Radler LLP

Sale of Mortgaged Property – Amount Realized or COD Income

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Do you feel as challenged as I do when someone asks you to explain the term “Bidenomics”? I know that it is predicated upon the imposition of higher taxes on businesses and their owners, which have not yet materialized....more

Rivkin Radler LLP

Corporate-Owned Life Insurance, a Redemption, and The Value of a Decedent’s Stock

Rivkin Radler LLP on

Estate Tax – It’s a Killer- One of the reasons often given for eliminating the estate tax is the substantial economic burden it places upon the estate of a deceased business owner and upon the business itself. Specifically,...more

Rivkin Radler LLP

Gifting Business Interests Before Selling the Business? Think Valuation

Rivkin Radler LLP on

Counting the Days?- We are 302 days away from the national mid-term elections, to be held November 8, 2022, yet the first full week of the new year has already highlighted some of the economic issues with which the...more

Rivkin Radler LLP

Not Selling Despite Tax Increases? Review the Buy-Sell Agreement Among Owners

Rivkin Radler LLP on

Not Selling Your Business This Year? Beginning shortly before the House Ways and Means Committee released its version of the President’s Build Back Better plan, several posts on this blog have explored the uptick in M&A...more

Rivkin Radler LLP

Step Transaction Or Substance Over Form? Loss Disallowance In Any Case

Rivkin Radler LLP on

The Dog Days- I’ve never much cared for the month of August. In New York, at least for me, the eighth month of the year – named by the Roman Emperor, Augustus, to honor himself – evokes memories of very warm, very humid...more

Farrell Fritz, P.C.

The “Art” Of Operating Foundations: A Public-Private Venture

Farrell Fritz, P.C. on

In the Beginning- From the dawn of recorded history, those who have the means have purchased or otherwise financed the work of those whom we call artists – talented individuals capable of producing what we call works of...more

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