Home/Tag: IRS

More on the Valuation Rules

The August recess has given the S-Corp team a little more time to review the pending valuations rules out of Treasury.  Recall that 23 years after the IRS surrendered and stopped using their flawed “family attribution” approach to valuing family-owned businesses, Treasury is trying to resurrect the concept using Section 2704.  Below are some additional thoughts about why this is a particularly bad and fatally flawed idea.

Scope:  Eliminating the application of “lack of control” and possibly “lack of marketability” discounts – the rule is unclear on those — to family business valuations may sound technical and immaterial, but

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2019-02-01T19:49:55+00:00August 30, 2016|

Courts Overvalue S Corps

For over 15 years, the IRS has discriminated against S Corporations when it comes to estate taxes and other matters where business valuation plays a role and, for 15 years, S Corp has been fighting them on it.

Our S-Corp advisor Nancy Fannon has written extensively on the subject. In 2007, we told you about her book, The Comprehensive Guide to S Corporation Valuation, which did a great job of laying out the entire issue.

Now, Nancy has followed up with Taxes and Value: The Ongoing Research and Analysis Relating to the S Corporation Valuation Puzzle. You can purchase the book

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2019-02-01T19:59:05+00:00May 14, 2015|

S Corp Payroll Tax Hike Resurfaces

Last week, Senate Democrats released a paper highlighting a dozen tax increases they would like to use to offset spending cuts in the current budget negotiations. As Politico reported:

Tax expenditures topping the list include the deduction corporations take when they move operations overseas and the carried interest loophole, which allows private equity and some other investment advisers to pay the lower capital gains tax rate on some of their income.

Also on the list is our old nemesis, the S corporation payroll tax hike. Labeled the Edwards Loophole by Republicans and the Gingrich Loophole by Democrats, the issue is

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2019-02-01T20:19:39+00:00November 14, 2013|

Senate to Consider Surtax

Senate Majority Leader Harry Reid (D-NV) reportedly plans to bring up the President’s Jobs Bill this month and pay for it with a new 5 percent “surtax” on taxpayers making more than a million dollars. According to Politico:

Senate Majority Leader Harry Reid is eyeing a tax on the nation’s highest earners as a way to defray some of the $447 billion price tag for the White House-written jobs package-a move that would shift attention away from its underlying policies and more towards party politics. Sources on and off Capitol Hill said Reid wants to swap out the bill’s current

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2019-02-01T20:24:44+00:00October 5, 2011|

More on Pass-Throughs and Corporate Reform

Last week, the Ways and Means Select Revenue Subcommittee held a hearing that sought to counter the momentum building within the Administration and in the press to tax pass-through businesses to pay for corporate-only tax reform.

Robert Carroll of Ernst and Young was one of the witnesses. As you’ll recall, S-CORP has asked Carroll to author a study on the economic importance of pass-through businesses and what impact corporate-only reform might have on them. His testimony last week touched on those themes and provided us with a nice preview of the study to come - including the news that pass-through firms

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2019-02-01T20:48:06+00:00March 8, 2011|