Nuances with Respect to Valuing a Controlling Ownership Interest
Market research and Internal Revenue Service guidance have confirmed that a controlling ownership interest in a business is more valuable than a similar noncontrolling ownership interest. Nevertheless, in particular instances, the governing documents of a business can limit the powers granted to a controlling ownership interest.
Proposed Regulation Changes to Circular 230
The Treasury Department and the Internal Revenue Service issued proposed regulations that apply to appraisers of real property, personal property, and businesses. The proposed regulations describe the appraisal standards that should be followed by appraisers when preparing appraisals that are submitted in an administrative proceeding before the Internal Revenue Service.
Estate Planning and Buy-Sell Agreements After the Connelly Decision
The Supreme Court was asked to decide a case that revolved around the obligation to redeem shares of a company. The court ruled that proceeds from company-owned life insurance related to a buy-sell agreement should be included when estimating the fair market value of the company for estate tax purposes.
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October 2024 Perspectives
- Key Considerations in the Valuation of Carried Interest from a Tax Perspective
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July 2024 Perspectives
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- Company Stock Repurchases at Fair Market Value May Deliver Value Accretion for Remaining Shareholders
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