The following are recommended
articles that we have published in
recent newsletters. Each discusses
important issues in valuation.
Section 409a and the value of
your stock plan - Internal Revenue Code Section 409A
restricts compensation deferrals for
income tax purposes. The
restrictions apply to most types of
deferred equity-based compensation,
including stock options, stock
appreciation rights (SARs) and
phantom stock plans.
IRS tightens the reins on
business valuations - The IRS has cracked down on abusive
tax reporting and upgraded its
Business Valuation Guidelines.
Understanding IRS preferences can
minimize taxpayer liabilities and
Estate tax valuations and
subsequent events - When appraised values seem to
contradict real-life transactions
Estate tax issues can be tricky.
Suppose a business owner dies or
gifts shares of his or her company
to family members. So far, so good.
But what if six months or a year
later, the company sells for
significantly more than its
previously appraised value? If the
IRS catches wind of this apparent
discrepancy, the family members may
receive a deficiency notice.
Don’t put estate planning on
the back burner - As a result of the estate tax repeal
scheduled for 2010, many people
mistakenly believe that estate
planning is no longer necessary.
4 Key IRS rulings at a glance
- The Treasury Department periodically
issues revenue rulings to help
interpret tax laws. These
interpretive rulings don’t carry the
same weight as the Internal Revenue
Code, but they do clarify complex or
ambiguous topics — including
business and intangible asset
What’s the IRS up to now?
The IRS has opposed family
limited partnerships (FLPs) —
largely unsuccessfully — since they
came into vogue in the 1990s.
Originally, its attacks centered on
substance over form and gift on
Taxpayer victory in the battle
over built-in capital gains tax
- No two ways about it: Built-in
capital gains tax is an economic
reality for C corporations. Recent
Tax Court rulings have forced the
IRS to concede that hypothetical
investors consider imbedded tax
liabilities when buying and selling