Unwrap all things estate and gift in this engaging session with Marissa Turrell and Carla Glass. This presentation will assume a basic understanding of business valuation, of both operating companies and holding companies, and focus on specifics related to valuing ownership interests for estate and gift purposes. Some topics will focus on issues that arise only in valuation for gift and estate purposes, such as seminal court cases on the matter, Chapter 14, working with the trust and estate attorney, and addressing IRS challenges. Other subjects will include issues that overlap with other areas of practice but that are either more common in gift and estate valuation or might have a special twist there. Examples of this second type of subject are addressing pass-through entity status, what’s key in the entity’s governing documents, market evidence for discounts, and what affects those discounts. Attend and you will come away with a better understanding of special considerations in performing valuations for gift and estate purposes.
Program Agenda
Background and primer—70 minutes: a. Revenue rulings and Chapter 14; b. Key seminal court cases; c. Special focuses on gift and estate reports; and d. Update on recent important cases.
Valuation techniques—65 minutes: a. Specific considerations of approaches to value; b. Cash-flow adjustments and level of value; c. Tax affecting pass-through entities; and d. Built-in capital gains.
Discounts—45 minutes: a. Operating company discounts for lack of control; b. FLP and LLC (holding company) discounts for lack of control; c. DLOM; and d. Multitiered.
Other—45 minutes: a. Working with an attorney; b. Other estate planning structures (freeze); c. IRS challenges; and d. Potential tax law changes.
Learning Objectives
Trace how seminal court cases and revenue rulings have shaped current valuations for gift and estate;
Participants will be provided helpful hints in addressing IRS challenges;
Describe Chapter 14 and when its consideration is key;
Restate examples of different treatment of pass-through status in valuation and learn about tax court cases involving pass-through treatment; and
Identify key elements of governing documents that affect discounts applicable to a subject interest—and the differences in market evidence used for support.
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