The Aftermath of the United States Supreme Court’s Decision in Connelly v. Internal Revenue Service: Q&As on its Meaning and the Ramifications on Future Planning, Particularly on Business Valuation
BVR's Webinar Series
Tuesday, July 30, 2024
10:00am-11:40am PT • 1:00pm-2:40pm ET
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The United States Supreme Court recently unanimously affirmed the Eighth Circuit in Connelly Est. v. Internal Revenue Service, Civ. No. 19-1410 2021, WL 4281288 (D.C. Sept. 21,2021), aff’d, sub nom., Connelly v. United States of America, Department of Treasury, Internal Revenue Service,70 F.4th 412 (8th Cir. 2023), aff’d, 602 U.S. ___ (June 6, 2024). During this 100-minute webinar, long-time co-collaborators Ed Morrow and Paul Hood, who’ve weighed in at every level of this case, discuss the decision and its potential ramifications on planning, particularly on business valuation.
Program Agenda
Brief review of the facts and the United States Supreme Court’s decision.
FAQs about the decision and its aftermath.
Must a qualified business appraiser consider any entity redemption obligation pursuant to the fair market value standard of value, notwithstanding the United States Supreme Court’s opinion in Connelly Est.? We’ll spend most of our time on this issue!
After the United States Supreme Court’s decision in Connelly Est., should estate planners be encouraging clients to revisit or review current buy-sell agreements?
Do all redemption buy-sell agreements need to be changed in light of the United States Supreme Court’s decision?
Did the United States Supreme Court either expressly or impliedly overrule or criticize the Eleventh Circuit’s decision in Blount Est. v. Comr.?
Did the United States Supreme Court either acknowledge or resolve, expressly or impliedly, any alleged circuit split in its Connelly Est. decision?
In its opinion in Connelly Est., did the United States Supreme Court rule out a subject company’s redemption obligations ever having a material adverse impact on the valuation of the subject company at the enterprise level?
Some pundits have made much out of the United States Supreme Court’s silence about IRC Sec. 2703-was that important?
What are the big lessons from the Connelly Est. decision?
Conclusion
Learning Objectives
Attendees will learn what the overall ramifications that the United States Supreme Court decision will have on future planning and business valuation.
Participants will be given an in-depth, 180-degree view on what a business appraiser must consider in valuing interests subject to a buy-sell agreement.
Registrants will learn how to work more effectively with tax and estate planning lawyers on buy-sell matters.
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