| How the IRS Values Non-Controlling Interests in S Corps with Job Aid Commentary by the Original IRS Champion (with CPE)
Program Type: Recorded Webinar(Audio, PPT Presentation) Program Level: Overview
Advanced Preparation: None
Delivery Method: Group Internet-Based
CPE Credits: Two (2) Hours
Fields of Study: Accounting (Governmental)
Shipping Weight: 0lbs. 0oz.
The IRS internal white paper entitled “The IRS Valuation of Non-Controlling Interests in Business Entities Electing to be Treated as S Corporations for Federal Tax Purposes” dated October 29, 2014 is reviewed to help you, the business appraiser, respond to the commentary.
This recently obtained IRS document presents background information from the perspective of the IRS. This document was written to help IRS professionals who are examining S Corp valuations. Major elements of this document are presented with Michael Gregory offering his insights as to what this might mean for business valuers providing S Corp valuations for federal tax purposes.
After completing this Webinar, attendees will be able to:
- Assess the most current thinking by the IRS when the IRS reviews an S Corp valuation
- Analyze what the IRS deems as not acceptable and potentially litigating vehicle approaches
- Describe how the IRS thinks the valuation should be completed
- Recognize what the IRS thinks of various court cases and tax affecting
- Identify from the presenter how you may want to respond going forward
Who Should Attend
Business valuation practitioners who want to be up to date on the IRS position on key business valuation concepts, methodologies and approaches
Michael Gregory, CVA, ASA, and Qualified Neutral, MN Supreme Court
Mr. Michael Gregory is the Chief Manager of Michael Gregory Consulting LLC focusing on issue resolution and business issues. Issue resolution includes both mediation and negotiation assistance on business issues and issues that involve tax controversies with the IRS. Value added services include reviews of expert reports for tax filings and litigation support as well as financial analysis and management development consulting.
He was an IRS territory manager with responsibilities for 23 states with an emphasis in the business valuation and engineering issues arena nationally over his last eleven years at the IRS. Mr. Gregory has championed the IRS internal teams on reasonable compensation, valuing subchapter S corporations, 409A, 6695A, and the Discount for Lack of Marketability. His engineering emphasis was in research credit and international issues.