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Join Michael Gregory for a discussion on two recently obtained internal IRS memorandums so that you can work more effectively with the IRS on estate and gift tax valuations. These memorandums shed light on how the IRS approaches valuing S corporation valuations and what you need to consider when preparing an S-corporation valuation for federal tax purposes. The memorandums recommend consideration of both Revenue Ruling 59-60 and the IRS Job Aid on Non-Controlling Interests. Key elements of these publications are shared and the applicability of the Job Aid on discount for lack of marketability are applied.
Program Agenda
Background
Focus on non-controlling S-corp Job Aid – Intro to Job Aid
IRS S-corps and Job Aid observations
IRS memorandum S-corporation valuation procedures received November 18, 2017
Background IRS memorandum S-corporation valuation procedures received January 4, 2018
Commentary for your consideration
Court case implications
Consider valuation approaches
Personal observations
Learning Objectives
Describe the background and gain insights into the IRS Job Aid on valuing non-controlling interests in S corps
Describe the IRS S corporation valuation procedures memorandums
Explain the potential ramifications of the IRS S corporation valuation procedures memorandums
Recite the steps to consider given the IRS S corporation valuation procedures memorandum
Describe now how to approach an audit by the IRS if tax affecting was applied to a non-controlling interest
List what mistakes to avoid should your appraisal be audited
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