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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.
Program Agenda
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?
Learning Objectives
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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