The IRS internal white paper “Reasonable Compensation Job Aid for IRS Valuation Professionals” dated October 29, 2014 is reviewed and available. This recently obtained IRS document, which was written to help IRS professionals who are reviewing reasonable compensation issues, presents background on the is topic area from the IRS perspective. In this insightful webinars, former IRS employee Michael Gregory provides insights to help business valuation professionals respond to this commentary. Major elements of this document are presented and Gregory offers his insights as to what this might mean for business valuers reviewing reasonable compensation issues while providing valuations for federal tax purposes.
Program Agenda
Summary of the Job Aid
Background and history of the Job Aid
Purpose, Background and Case Coordination
Suggested readings: James Hitchner, Melanie McCoskey, Shannon Pratt, Ron Seigneur and Kevin Yeanoplos, BNA Portfolio
Cautions
Identifying a reasonable compensation issue
Sources – paid for by IRS
Free sources
Developing reasonable compensation issues
Factual development - five information document requests
Financial analysis – example in Appendix D
Market – example in Appendix E
Income – example in Appendix F
Cost approach
Reconciliation
Taxpayer Arguments for Reasonable Compensation Issues
Prior years’ under compensation
Multiple jobs
Independent investor test
Employee personally guarantees debt
Key person
Consideration of penalties
Focusing specifically on not-for-profits
Note in Appendix I nine-step process
Discussion on loans for not-for-profit and for-profit entities
Key fringe benefits identified
Compensation and benefits issue practice group (IPG) subject matter experts (SME)
Learning Objectives
Learn the most current thinking by the IRS when the IRS reviews reasonable compensation
Learn what the IRS deems the most appropriate data sources and their limitations regarding reasonable compensation
Understand how the IRS thinks the issue of reasonable compensation should be approached
Understand what the IRS thinks of various court cases associated with different aspects of the issue
Gain insight from the presenter on how you may want to respond going forward
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