News & Analysis as of

Asset Valuations Internal Revenue Service

J.S. Held

The Essential Role of Qualified Personal Property Appraisers in Estate and Donation Valuations

J.S. Held on

When purchasing an expensive engagement ring, one would not seek the expertise of a real estate agent. Similarly, when an estate requires an appraisal, it is crucial to engage the appropriate expert for high value personal...more

Opportune LLP

5 Crucial Valuation Elements for Gift and Estate Tax

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Over time, personal and corporate income taxation tends to receive most of the media's and the public's attention. However, it’s important to remember that gift and estate taxes can also profoundly impact an individual’s...more

Opportune LLP

Understanding Gift & Estate Tax Valuation

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The requirements outlined in the tax code can significantly impact an individual’s gift and estate planning, and navigating these requirements effectively is crucial. In this blog post, we will delve into gift and estate tax...more

Polsinelli

New York Alleges Trump Procured Inflated Appraisals for Conservation Easements

Polsinelli on

On September 21, 2022, the New York State Attorney General Tish James filed a civil lawsuit against former President Donald Trump and the Trump organization alleging fraud and misrepresentation. The Complaint described a...more

Foster Garvey PC

House of Representatives 5376: Current Tax Legislation Pending in the U.S. House of Representatives

Foster Garvey PC on

...The federal tax laws are certainly about to change. With the need to raise revenue as a top priority for the Biden Administration, everyone is expecting dramatic changes to the Internal Revenue Code. Tax legislation is...more

Bowditch & Dewey

Prince’s Controversy: A Cautionary Tale of Improper Estate Planning

Bowditch & Dewey on

The controversy surrounding the wealth left behind by Prince after his sudden death in 2016 is heating up again after the IRS determined that Prince’s estate is worth approximately $163 million, or twice what his estate...more

Robins Kaplan LLP

The Robins Kaplan Spotlight - VOL. 5, NO. 3 Fall 2020

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The Spotlight is the result of ongoing collaboration between our national trial practice and estate planning groups, with the goal of providing a forum to discuss the latest news and other issues impacting the trusts and...more

McDermott Will & Emery

Weekly IRS Roundup February 3 – 7, 2020

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 3 – 7, 2020. February 3, 2020: The IRS and the Departments of Labor and Health and...more

Stinson LLP

Opportunity Zone Final Guidance

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The Treasury Department released final Opportunity Zone regulations on December 19, which combine and clarify the prior two sets of guidance, as well as an FAQ summary....more

Miles & Stockbridge P.C.

2nd Tranche of OZ Regulations

On April 16, 2019, Treasury issued its second set of proposed regulations (“OZ Regs 2”) regarding Section 14002 of the Internal Revenue Code of 1986, as amended (the “Code”). The OZ Regs 2 are very helpful and answer a...more

Skadden, Arps, Slate, Meagher & Flom LLP

New Guidance for Opportunity Zone Funds Clarifies Important Issues, Leaves Door Open to Additional Guidance

The Treasury Department and the Internal Revenue Service (IRS) recently released much-anticipated proposed regulations, as well as a related revenue ruling (Rev. Rul. 2018-29), concerning opportunity zone investments....more

Sheppard Mullin Richter & Hampton LLP

Opportunity Zones Update

Background – In December 2017, as part of the Tax Cuts and Jobs Act (“TCJA”), Congress established a new tax incentive program to promote investment in certain low-income communities designated by the IRS as qualified...more

Katten Muchin Rosenman LLP

2016 Year-End Estate Planning Advisory

In 2016, we continued to experience a period of relative stability in our federal transfer tax system and have been able to plan without expecting imminent significant changes to the system. Under the American Taxpayer Relief...more

Akin Gump Strauss Hauer & Feld LLP

IRS Proposes Regulations to Limit Valuation Discounts for Family Businesses

On August 2, 2016, the Internal Revenue Service and the Treasury Department issued proposed regulations intended to substantially limit the use of discounts in valuing intra-family transfers of interests in family-controlled...more

Troutman Pepper Locke

Changes Coming to the Long-Term Tax Exempt Rate Used in Calculating Section 382 Limitations - Tax Update Volume 2016, Issue 1

Troutman Pepper Locke on

Changes to the formula for determining the long-term tax-exempt rate used in a section 382 limitation calculation after a company undergoes an ownership change may lower the amount of net operating losses the company can use...more

Clark Hill PLC

Potential Limitations on Gift Tax Strategies Coming Soon

Clark Hill PLC on

Valuation discounts have been a significant component of estate planning for many years. By contributing assets to a family entity and gifting or selling an interest in the entity to family members, you can effectively...more

McDermott Will & Emery

OECD/BEPS Intangibles Revisions to Change Character, Treatment of Goodwill

McDermott Will & Emery on

Corporations acquiring intangible assets as part of business combination will no longer be able ignore goodwill in their subsequent restructurings and asset transfers. That’s the upshot from tax authorities from around the...more

Williams Mullen

Fifth Circuit Court Reverses Tax Court Ruling on Fractional Interest Valuation Discounts

Williams Mullen on

On September 15, the U.S. Court of Appeals for the Fifth Circuit reversed a 2013 Tax Court decision that had allowed only a nominal, 10% fractional interest discount for artwork included in a decedent’s estate....more

Eversheds Sutherland (US) LLP

Legal Alert: U.S. Supreme Court Resolves Circuit Split: Holds Valuation Misstatement Penalty Applies in Partnership Tax Shelter...

On December 3, 2013, the U.S. Supreme Court unanimously reversed the U.S. Court of Appeals for the Fifth Circuit and held that (1) a federal district court in a partnership-level proceeding had jurisdiction to determine the...more

BakerHostetler

Tax Court Rules that IRS Too Aggressive in Applying Qualified Appraisal and Qualified Appraiser Standards

BakerHostetler on

In Friedberg v. Comm’r, T.C. Memo 2011-238, the Tax Court granted summary judgment for the IRS, holding that an appraisal used to substantiate a facade easement donation amount was not a qualified appraisal because it...more

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