Business & Tax Blog

The simple answer is that the IRS believes that valuation discounts taken on family-controlled entities are falsely high, which results in lower transfer tax revenue to the Treasury. With the foregoing in mind, it is important to understand how the IRS, courts, and taxpayers value a business interest under current…

The Internal Revenue Code prescribes minimum imputed interest rates and time-value-of-money factors applicable to certain loan transactions and estate planning techniques. These rates are tied formulaically to market interest rates. The Internal Revenue Service updates these rates monthly. These are commonly applicable rates in effect for September 2016: Short Term AFR…

If you want to convert a substantially appreciated asset into a diversified asset portfolio without paying capital gains tax, choose your favorite Presidential candidate with extra care. He or she could save you a lot of tax by giving you a job. If that candidate becomes President, appoints you to…

A 1031 Exchange is a popular capital gains deferral strategy for business and investment property. Taxpayers use the strategy to defer capital gains tax on property “sold” by acquiring “like-kind” replacement property, usually in coordination with an intermediary or accommodation party. After deliberating for a decade, the U.S. Tax Court…

The Treasury has followed through on its promise to issue proposed regulations that are intended to significantly reduce the lack of control and lack of marketability discounts applied by appraisers when valuing family-controlled entities. The proposed regulations follow closely with guidance provided in the Treasury Department’s “Greenbook” as discussed in…