Valuation, Discount Strategies and Tax Savings (Currently Unavailable)

Author: Owen G. Fiore

Valuation is a core concept in taxation, with the hypothetical party FMV standard of value well-established. However, the subjectivity surrounding this standard of value requires careful planning and implementation of transactions that have valuation discounts as one of their goals.
With over 100 pages of course materials and discussion of actual "real life" case studies in valuation, course participants will be provided with insights in "Playing the Valuation Game".

Publication Date: March 2014

Designed For
CPAs, CFPs, Enrolled Agents and other tax professionals

Topics Covered

• Review of a number of Special Valuation Rules
• AFR minimum interest rule of IRC Sec. 7872 and the Chapter 14 provisions which are IRC Secs. 2701-2704
• Possible legislation on valuation issues will be considered and IRS audit strategies reviewed.

Learning Objectives

• Understand and apply basic principles of valuation for tax planning, including the "10 key concepts in valuation" reviewed in the course.
• Identify valuation issues in structuring entities and in documenting property and entity interest transactions both within the family and involving non-family key managers.
• Understand and use in planning the Special Valuation Rules of Chapter 14, especially as to split-interest trusts (GRATs and QPRTs) and Buy-Sell Agreements, plus consider use of the AFR minimum interest rules of IRC Sec. 7872.
• Apply tax valuation principles and possible discount strategies to closely-held business and investment equity interest transfers.
• Understand planning lessons learned from review of valuation court decisions and IRS rulings, informal guidance and Treasury Regulations.

Level
Basic

Instructional Method
Self-Study

NASBA Field of Study
Taxes (2 hours)

Program Prerequisites
None

Advance Preparation
None