Business valuations prepared for federal tax transactions are at the core of the valuation practice of Business Valuation Analysts, LLC (or “BVA”), for good reason, we are recognized experts in this challenging area of valuation practice.  BVA professionals possess the knowledge, skills and experience necessary to construct, substantiate and document value opinions for maximum effectiveness for use in federal tax transactions.

pdf Recent Valuation Resolutions

As evidence of our expertise in federal tax valuation matters, we are frequently asked to lecture to institutions of higher learning and professional organizations about federal tax valuation such as:

  • University of Miami Heckerling Institute on Estate Planning
  • Graduate Tax Program, University of Florida Levin College of Law
  • University of Florida Levin College of Law
  • University of South Florida, St. Petersburg; MBA/Program of Accountancy
  • American Bar Association, Real Property, Trusts and Estates Section
  • American Bar Association, Tax Section
  • Florida Bar Real Property, Probate and Trust Law Section
  • Florida Bar Tax Section
 

In many situations, valuation has a central role in tax planning, administration and compliance involving corporate income taxes, estate and gift taxes, or personal income taxes.  Given the transparency required by Internal Revenue Service, a well substantiated and documented business valuation is an integral component required to successfully execute tax planning strategies or realize optimal tax compliance results.  In the event the tax transaction is scrutinized, a valuation prepared by BVA places the client in a position of strength to reach a favorable resolution at an early stage.

BVA possesses significant valuation experience in situations involving the following federal tax transactions:

  • Estate and Gift Tax Transactions

    Estate tax administration and planning – IRC §2031
    Gift tax administration and planning – IRC §2512
    Estate and gift tax controversies – valuation consulting

  • Income Tax Transactions

    Allocation of value, determination of professional goodwill
    C corporation to S corporation conversion – IRC §1374
    Charitable contributions – Reg. §1.170A-13(c)(2)
    Compensation planning – IRC §83(b)
    Compensation in kind
    Corporate recapitalizations
    Corporate reorganizations
    Divestitures
    Income tax controversies – valuation consulting
    Net operating loss (NOL) carryforwards – IRC §382
    Not-for-profit – IRC §501(c)(3)

  • Federal Tax Valuation Resources

    Resources

    Recent Valuation Resolutions→

    Presentation to Graduate Tax Program, University of Florida Levin College of Law, June 10, 2014

    “Business Valuation in a Federal Tax Environment – Techniques to Enhance Appraisal Effectiveness”, Valuation Strategies, Volume 6, Number 5, May/June 2003, pp. 4-13, 45 & 46

    “An Estate Planning Attorney’s Guide to Business Valuations, Part Three”, West Group’s Estate & Personal Financial Planning, January 2000, pp. 1-13 (co-author)

    “An Estate Planning Attorney’s Guide to Business Valuation, Part Two”, West Group’s Estate & Personal Financial Planning, December 1999, pp. 1-22 (co-author)

    “An Estate Planning Attorney’s Guide to Business Valuation, Part One”, West Group’s Estate & Personal Financial Planning, November 1999, pp. 1-14 (co-author)

  • Internal Revenue Service Guidance on Valuation

    Selected Internal Revenue Service Code Sections on Valuation
    §1.170A-17 Qualified appraisal and qualified appraiser
    §409A Inclusion in gross income of deferred compensation under nonqualified deferred compensation plans
    §1060 Special allocation rules for certain asset acquisitions
    §1374 Tax imposed on certain built-in gains
    §2031 Definition of gross estate
    §2032 Alternate valuation
    §2036 Transfers with retained life estate
    §2044 Certain property for which marital deduction was previously allowed
    §2011 Transfers in general
    §2511 Valuation of gifts
    §2701 Special valuation rules in case of transfers of certain interests in corporations or partnerships
    §2702 Special valuation rules in case of transfers of interests in trusts
    §2703 Certain rights and restrictions disregarded
    §2704 Treatment of certain lapsing rights and restrictions
    §6501 Limitations on assessment and collection
    §6662 Imposition of accuracy-related penalty on underpayments

    Selected Internal Revenue Service Regulations Related to Valuation
    §1.170A-13(c)(3) Qualified appraisals for charitable income tax transfers
    §20.2031-1 Definition of gross estate; valuation of property
    §20.2031-2f Valuation of stocks and bonds
    §20.2031-3 Valuation of interests in businesses
    §25.2703-1 Property subject to restrictive agreements
    §25.2703-2 Effective date
    §25.2704-2 Transfers subject to applicable restrictions
    §301.6501(c)-1 Exceptions to general period of limitations on assessment and collection

    Selected Internal Revenue Service Rulings and Procedures Related to Valuation
    Revenue Ruling 59-60 Valuation of closely held corporations, estate tax and gift tax
    Revenue Ruling 65-192 Valuation of closely held corporations, income tax
    Revenue Ruling 65-193 Valuation of intangible assets of a business
    Revenue Procedure 66-49 Appraisals of donated property for federal income tax purposes
    Revenue Ruling 68-609 Application of formula approach for valuing intangible assets
    Revenue Procedure 77-12 Valuation involving the allocation of assets acquired through an asset purchase or subsidiary merger
    Revenue Ruling 77-287 Valuation of securities restricted from immediate resale
    Revenue Ruling 83-120 Valuation of closely held preferred and common stock received in certain corporate reorganizations
    Revenue Ruling 85-75 Addition to tax in the case of valuation overstatements for income tax purposes
    Revenue Ruling 93-12 Valuation of minority interests in intrafamily transfers

    Other Internal Revenue Service Guidance Related to Valuation
    Internal Revenue Service Valuation Training for Appeals Officers
    UIL 2031.01-00, Appeals Coordinated Issue Settlement Guidelines, Discounts for Family Partnerships
    Internal Revenue Manual (IRM) 4.48.4, Engineering Program, Business Valuation Guidelines
    Internal Revenue Manual (IRM) 8.18.1, Valuation Assistance Procedures