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Internal Revenue Code (IRC) Valuation

ArentFox Schiff

The Big Six Items That Family Offices Need to Consider in 2025

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Across all industries, family offices and their owners and management teams face rapidly evolving challenges, opportunities, and risks in the dynamic environment that is 2025. Here are six issues that family offices should...more

Proskauer Rose LLP

Wealth Management Update - March 2025

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March 2025 AFRs and 7520 Rate - The March 2025 Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 5.40%, which was the same as the February 2025 rate...more

Ankura

The Critical Importance of Tax Due Diligence in Modern Business Transactions

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In today's complex and ever-evolving business landscape, tax due diligence has emerged as a critical component of financial analysis and risk management in mergers, acquisitions, and other significant business transactions....more

Bricker Graydon LLP

Do I Need a 409A Valuation for my Company?

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If you have equity as part of your retirement or executive compensation plans, you likely need a 409A valuation. The need for a valuation also applies if you are preparing to issue equity (equity grants or stock options) or...more

DarrowEverett LLP

How Will New Congress Impact Tax and Estate Planning Strategies?

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With the looming elections, tax planners have taken time to consider what the future of Estate and Gift Tax planning might be under the new Congress. Every new Congress considers changes to the Internal Revenue Code of 1986,...more

Pillsbury - Propel

Equity Compensation: Navigating 409A Valuations

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Private company clients frequently ask us about granting compensatory stock options to their founders, employees and other service providers, including board members, consultants and advisors. Options and other equity awards...more

Proskauer - Tax Talks

Senate Finance Committee Requests Public Comments on Digital Asset Taxation

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On July 11, 2023, the Senate Finance Committee released an open letter to the Digital Asset Community asking a variety of questions in connection with possible future legislation. Public comments must be emailed to the Senate...more

ArentFox Schiff

Self-Directed IRAs and the Prohibited Transaction Rules – Part 1

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Part 1: Permitted Investments and Compliance - The self-directed individual retirement account (IRA) is an increasingly popular option for an IRA account owner, especially those owners who have significant net worth and...more

McDermott Will & Emery

IRS Releases Memorandum on Deducting Cryptocurrency Losses

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On January 13, 2023, the Internal Revenue Service (IRS) released a Chief Counsel Advice Memorandum (CCA 202302011) concluding that taxpayers cannot claim a deduction for cryptocurrency losses that have, absent a sale or other...more

King & Spalding

IRS and Treasury Issue Interim Guidance on 1% Stock Buyback Tax

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On December 27, 2022, the IRS and Treasury issued Notice 2023-2 (the “Notice”), which provides guidance relating to the application of the new excise tax on repurchases of corporate stock (the “Stock Buyback Tax”) under...more

Freeman Law

Tax Court in Brief | Brooks v. Comm’r | Charitable Contribution Deductions for Conservation Easement; Contemporaneous Written...

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Tax Litigation:  The Week of December 19th, 2022, through December 23rd, 2022 Starer v. Comm’r, T.C. Memo. 2022-124 | December 20, 2022 |Wells, J. |Docket No. 615-13 Mamadou v. Comm’r, T.C. Memo. 2022-121 | December 20, 2022...more

Foley & Lardner LLP

Common Diligence Issues for Startup and Emerging Technology Companies

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As an emerging or startup technology company seeking funding, your focus is likely on your product - it is the core of your business. That being said, how you protect your technology and set up the company that owns it can be...more

Pillsbury Winthrop Shaw Pittman LLP

SEC Moves to Modernize Framework for Securities Offerings and Sales to Workers

The SEC takes a highly anticipated first step toward updating Rule 701 and Form S-8 - Amendments to Rule 701 would increase the cap on exempt offerings and ease disclosure burdens. Revisions to Form S-8 would permit...more

Troutman Pepper Locke

Disappearing Discounts?: IRC 2704 Proposed Regulations Threaten Valuation Discounts for Transfers of Interests in...

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Purpose of Section 2704 - Internal Revenue Code Section 2704 was originally passed to restrict certain types of valuation discounts on transfers of ownership interests in family-owned businesses among family members....more

Goodwin

IRS Proposes Valuation Discount Regulations: Implications for Family-Controlled Businesses

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IRS issues new proposed rules aimed at eliminating valuation discounts for transfers of interests in family-controlled entities. Clients considering making transfers of interests in such entities should act soon....more

McNees Wallace & Nurick LLC

IRS Proposes New Rules for Valuing Interests in Family-Owned Businesses

Earlier this month, the IRS issued long-awaited proposed regulations under Section 2704 of the Internal Revenue Code that, if adopted, will have a substantial impact on traditional estate planning techniques commonly utilized...more

McAfee & Taft

Proposed IRS regulations will limit valuation discounts for family-held entities

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On August 2, 2016, the Internal Revenue Service (IRS) released proposed regulations that, when finalized, will affect clients holding and transferring interests in family-controlled entities. Family limited partnerships...more

Davis Wright Tremaine LLP

Proposed Regulations Would Curtail Most Valuation Discounts for Family-Owned Businesses – 2016 Planning Opportunity

Recently proposed Treasury Regulations (“Proposed Regulations”), if enacted as proposed, would curtail valuation discounts that currently reduce the value of certain business interests transferred during life or at death for...more

Blank Rome LLP

Act Now to Avoid Proposed IRS Rules Which Would Eliminate Valuation Discounts for Intra-Family Transfers of Interests in Family...

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Action Item: Owners of family businesses and investment entities (such as family limited partnerships, limited liability companies (“LLCs”), and corporations) are urged to consider making transfers of interests in those...more

Farella Braun + Martel LLP

Proposed Section 2704 Regulations Would Impose Significant Restrictions on Valuation Discount Planning for Family Controlled...

High net worth families often utilize family entity structures, such as limited partnerships or limited liability companies, in order to provide for the coordinated management of family assets and move wealth to younger...more

Bond Schoeneck & King PLLC

Trust and Estate: Time-Sensitive: Give it Away While There is Still Time (8/16)

Proposed Regulations for Internal Revenue Code § 2704 Significantly Limit Valuation Discounts for Intra-Family Transfers - On August 2, 2016, the United States Department of the Treasury (the "Treasury Department")...more

Saul Ewing LLP

Treasury Proposes Regulations That Will Limit Valuable Asset Transfer Techniques for Families

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On August 2, 2016, the Internal Revenue Service released proposed regulations under section 2704 of the Internal Revenue Code, which could cause dramatic changes to valuation discounts - one of the most valuable transfer...more

Proskauer Rose LLP

Valuation Discounts for Transfers of Interests in Family Entities May Be Severely Curtailed – You May Want To Act Now

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On August 2, 2016, the Treasury Department and the Internal Revenue Service (the "IRS") issued proposed regulations under section 2704 (the "Proposed Regulations") of the Internal Revenue Code of 1986, as amended (the...more

McGuireWoods LLP

Proposed Section 2704 Regulations Would Impose Major Restrictions on Valuation Discount Planning

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Long-awaited proposed regulations under section 2704 of the Internal Revenue Code, released on August 2, 2016, would make sweeping and very significant changes to the valuation of interests in many family-controlled entities...more

Tucker Arensberg, P.C.

Fiduciary Alert: IRS Again Extends Time for Consistent Basis Reporting via Form 8971 until June 30, 2016

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Effective March 23, 2016, the Treasury Department and Internal Revenue Service published Notice 2016-27, once again extending, until June 30, 2016, the deadline for executors and other persons to complete and file Form 8971...more

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