Christine Walizer, Author at The S Corporation Association

Response to Valuation Rules Continues

The Main Street Employers coalition sent a letter to congressional tax writers yesterday opposing the proposed rules on estate valuations and calling on Congress to weigh in with Treasury on the issue. From Politico:

The business community is escalating its efforts to beat back new Treasury regulations on the estate tax, which have somewhat fallen under the radar due to all the attention given to the Section 385 earnings stripping rules. A coalition called Parity for Main Street Employers sent leading congressional tax writers a letter asking Congress to urge Treasury to pull back rules that would make it harder …

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admin2019-02-01T19:49:54+00:00September 23, 2016|

Business Community Responds to Valuation Rules

Business Valuation Wire reports there has been a sharp spike in the number of families asking valuation professionals to analyze what the newly proposed rules out of Treasury mean to their business succession plans:

Valuation practitioners tell BVWire they are already seeing an increase in valuation engagements triggered by the proposed Section 2704 regulations. And they expect this to gain steam as the regs continue to sink in with attorneys, wealth planners, and clients.

This should not come as a surprise. The proposed rules target family businesses for higher estate and gift taxes, simply for being family-owned businesses. They accomplish this …

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admin2019-02-01T19:49:55+00:00September 16, 2016|

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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admin2019-02-01T19:49:55+00:00August 30, 2016|

Pass Through Loopholes?

The pass through mantra, supported by more than 100 national business trade groups, is simple – tax business income once, tax it when its earned, tax it at the same reasonable top rate, and then leave it alone!

Do you want to stop inversions and keep American corporations here at home? Adopt the mantra. Do you want to make sure Main Street continues to be a source of job creation and economic stability? Adopt the mantra.

We’ve been on this message for five years, and sometimes you get the sense it’s starting to sink in. For example, the Brady blueprint …

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admin2019-02-01T19:56:24+00:00August 15, 2016|

Treasury Hits Family Businesses!

The verdict is in, and Treasury’s proposed rules on estate tax valuations of family-owned businesses are broad – very broad indeed. They are, simply put, a direct assault on America’s family-owned businesses.

Here’s the take of WealthManagement.Com:

Although the details are significant, the bottom line is that the proposed regulations would appear to eliminate almost all minority (lack of control) discounts for closely held entity interests, including active businesses owned by a family. To accomplish that, restrictions under the governing documents and even those under state law would be disregarded for valuation purposes.

And Steve Leimberg’s Estate Planning Email Newsletter:

In short, …

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admin2019-02-01T19:56:24+00:00August 9, 2016|