Pass-Through Entity Discounts for Built-In Capital Gains Taxes
Part 4 of BVR's 5th Annual Online Symposium on Estate and Gift Tax
Tuesday, January 8, 2013
12:00am-2:00am PT • 3:00am-5:00am ET
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Through Jensen, Dunn, Jelke, and other cases, courts have weighed in on the methodologies and practices used in assessing the value of pass-through entities, like family limited partnerships and limited liability corporations, and C Corps. In doing so they have left both guidance and confusion as to the treatment of built-in capital gains taxes. In this webinar, part 4 of BVR's 5th Annual Symposium on Estate & Gift Tax, experts Mel Abraham and William Frazier join BVR to discuss these and other issues relating to built-in capital gains taxes. Hear what appraisers should know and consider in order to produce a more defensible conclusion of value in this tricky area.
- Historical overview
- C Corp cases
- Evolution of valuation methodology
- Valuation issues
- Built-in gains in S corps
- Court cases
- C to S conversions and the recognition period
- S corps (no recognition period)
- Built-in gains in other LLCs and FLPs
- Is this appropriate?
- How is it measured?
- Learn how built-in capital gains taxes have driven valuation methodologies and practices
- Learn how the courts have treated pass-through entities with regard to built-in capital gains taxes
- Understand how judicial decisions have affected valuation practices
- Learn how built-in capital gains taxes are treated across various types of pass through entities
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