Christine Walizer, Author at The S Corporation Association

The Short, Unhappy Life of the 2704 Valuation Rules

Do family businesses still need to worry about the 2704 valuation rules? These rules have consumed the attention and resources of family businesses nationwide since they were first proposed back in August. While we have been assured there is no plan to finalize the rules before the end of the current administration, many families are still wary of their potential impact if they were allowed to take effect. So, will the rules move forward in 2017? Or will the new tax leadership taking control ensure they go away?

Ways & Means Chairman Kevin Brady (R-TX) helped provide clarity on that question …

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admin2019-02-01T19:49:54+00:00November 22, 2016|

Tax Reform Front and Center

Last week’s election changed everything in the tax world, from who’s running Treasury to the prospects for tax reform. We’re still trying to get our heads around all the implications, but the short summary is that S-Corp just went from playing defense all the time (which is not fun, as you can imagine) to being able to focus our efforts on a more positive and proactive agenda (which is much better).

First and foremost, comprehensive tax reform is now on the table, whereas before it was simply not going to happen. Sure, people talked about doing tax reform under a prospective …

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admin2019-02-01T19:49:54+00:00November 18, 2016|

2704 Comment Period Closes Big

The official comment period on the proposed Section 2704 regulations closed yesterday, with nearly 10,000 comments filed! You can review those comments here, but a cursory review this morning made clear they were nearly unanimous in their opposition to the Treasury action.

Eventually, all the comments submitted will be accessible at the regulations.gov website, but until then, here are some of the more significant comment letters we’ve seen. Definitely worth a read if you have clients or businesses affected by the proposed rule:

S Corporation Association
Family Business Estate Tax Coalition (NFIB-led coalition)
American Institute of Certified …

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admin2019-02-01T19:49:54+00:00November 3, 2016|

S-Corp Submits Valuation Comments

Yesterday, the S Corporation Association submitted its formal comments to the IRS on the pending Section 2704 valuation rules. You can read all 15 pages of comments here, but the basic message of the submission was that Treasury should discard this effort and start over. As the comments conclude:

Promulgation of the Proposed Regulations in their current form and scope will generate significant uncertainty and constitute a significant impediment for the continuity of family-controlled businesses. The Proposed Regulations inappropriately and illegally discriminate against family controlled businesses in form and effect. If Treasury is inclined to promulgate regulations to address perceived …

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admin2019-02-01T19:49:54+00:00October 18, 2016|

S Corps Exempted from 385 Rules

Here’s a bit of good news for the S corporation community – Treasury has exempted them from the newly published rules under Section 385.

This is a huge relief to the S corporation community. The rules would have hit S corporations the hardest, despite them having no skin in the “base erosion” game. S corporations would have suffered through the new reporting requirements and limitations on cash pooling and related party loans just like their C corporation counterparts, but they also would have faced the prospect of losing their S corporation status, together with the multitude of tax and penalty …

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admin2019-02-01T19:49:54+00:00October 14, 2016|