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Valuation Internal Revenue Service Fair Market Value

Levenfeld Pearlstein, LLC

Redemption Agreements and Life Insurance Proceeds: What the SCOTUS Decision in Connelly Means for Closely Held Businesses

Many closely held businesses have shareholder buy/sell redemption agreements. These agreements are critical to maintaining business continuity when a key shareholder exits the company. When the redemption agreement is...more

Dinsmore & Shohl LLP

Connelly Decision: Supreme Court Rules Company-Owned Life Insurance Must Be Included in Estate Valuation

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A recent Supreme Court decision means that owners of closely held companies with company-owned life insurance policies should take extra precautions to avoid an unexpectedly large estate tax bill from the IRS....more

Ankura

FIRPTA - A Practical Approach to the Valuation Exercise

Ankura on

An often unknown yet potentially costly tax can emanate from the Foreign Investment in Real Property Tax Act, known as “FIRPTA.” In the following, we discuss a pragmatic approach to the valuation exercise, which is a key part...more

Lathrop GPM

Supreme Court Confirms Life Insurance Proceeds Received by Corporation Increase Estate Tax Value of Decedent’s Shares

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The June 6 unanimous ruling by the United States Supreme Court in Connelly v. United States creates a significant change for closely held businesses planning to utilize life insurance proceeds to fund buy-sell agreements....more

Rivkin Radler LLP

Estate, Gift, GST & Related Income Tax Proposals – What is the White House Doing?

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Earlier this week the White House released its Fiscal Year 2025 Budget. Of course, the federal government has not yet adopted a budget for the Fiscal Year 2024 even as we approach that year’s halfway mark. But I digress. The...more

Mintz - Venture Capital & Emerging Companies...

Section 409A Valuations: Mastering the Art and Science in a Volatile Venture Market

Within the unpredictable landscape of start-ups and private companies, market volatility can significantly alter a company’s financial trajectory. An integral part of navigating this volatility is understanding the role and...more

ArentFox Schiff

Self-Directed IRAs and the Prohibited Transaction Rules – Part 1

ArentFox Schiff on

Part 1: Permitted Investments and Compliance - The self-directed individual retirement account (IRA) is an increasingly popular option for an IRA account owner, especially those owners who have significant net worth and...more

King & Spalding

IRS and Treasury Issue Interim Guidance on 1% Stock Buyback Tax

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On December 27, 2022, the IRS and Treasury issued Notice 2023-2 (the “Notice”), which provides guidance relating to the application of the new excise tax on repurchases of corporate stock (the “Stock Buyback Tax”) under...more

Rivkin Radler LLP

Gift Transfers: Not on the Congressional Agenda, But Still in the Crosshairs of the IRS

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Same old in D.C.- On Monday, November 15, the President will sign into law the approximately $1 trillion Infrastructure Investment and Jobs Act that was finally passed by Congress when the House approved the Senate’s...more

Holland & Hart - The Benefits Dial

I’ll Be a Child of the Wind…At Least Until I Get a Retroactive 409A Valuation

Most private companies are now well aware that the valuation methods under Code Section 409A are for the purpose of granting Section 409A exempt “stock rights” which include employee stock options with a requirement, among...more

Rivkin Radler LLP

Biden’s 2022 Revenue Proposal, Profits Interests, And The Alchemy Of Compensation

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Recap- Last week, we considered several of the revenue proposals included in the Biden Administration’s 2022 Budget that are probably of interest – or should we say, “of concern”? – to the owners of closely held...more

Opportune LLP

Gift & Estate Tax Valuation: 5 Things To Remember

Opportune LLP on

Here are five things to remember when performing the valuation of shares of a closely held entity for gift and estate tax reporting...more

Farrell Fritz, P.C.

Valuation, Hindsight, And Taxes

Farrell Fritz, P.C. on

The Benefit of Knowing- Monday morning quarterbacking – the connotations are anything but positive. Life is full of instances in which someone, in possession of all the factors that informed – or that should have...more

Greenberg Glusker LLP

Transfers of Family-Controlled Business Entities to Family Members Could Get More Expensive

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Transfers of Family-Controlled Business Entities to Family Members Could Get More Expensive - The Internal Revenue Service (IRS) recently released proposed regulations that will dramatically change the valuation of...more

Burns & Levinson LLP

IRS Proposes Regulations That Will Eliminate Most Valuation Discounts on Family-Owned Entities

Burns & Levinson LLP on

On August 2, 2016, the IRS issued proposed regulations that would eliminate or limit the use of certain valuation discounts regularly applied when valuing interests in family-owned entities for gift and estate tax purposes. ...more

McAfee & Taft

Proposed IRS regulations will limit valuation discounts for family-held entities

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On August 2, 2016, the Internal Revenue Service (IRS) released proposed regulations that, when finalized, will affect clients holding and transferring interests in family-controlled entities. Family limited partnerships...more

Blank Rome LLP

Act Now to Avoid Proposed IRS Rules Which Would Eliminate Valuation Discounts for Intra-Family Transfers of Interests in Family...

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Action Item: Owners of family businesses and investment entities (such as family limited partnerships, limited liability companies (“LLCs”), and corporations) are urged to consider making transfers of interests in those...more

K&L Gates LLP

IRS Plans to Disallow Minority Interest Discounts for Family-Controlled Entities; Action May Be Required Before Year-End

K&L Gates LLP on

Gifts and bequests of interests in family-owned companies have traditionally been valued at their fair market values for purposes of calculating the gift or estate tax on the transfer. In valuing these transfers, there is...more

Hinshaw & Culbertson LLP

Higher Taxes Projected for Transfer of Minority Interests in Hard to Value Assets

On August 2nd the U.S. Department of the Treasury announced proposed regulations to limit or possibly eliminate a strategy long utilized to reduce the fair market value of certain assets transferred during life or at death to...more

McGuireWoods LLP

Proposed Section 2704 Regulations Would Impose Major Restrictions on Valuation Discount Planning

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Long-awaited proposed regulations under section 2704 of the Internal Revenue Code, released on August 2, 2016, would make sweeping and very significant changes to the valuation of interests in many family-controlled entities...more

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