Valuing Interests in S-Corps

Friday, December 6, 2013

Mike presents his perspective having led a team at the IRS on valuing S corporations and discusses the inconsistencies in application at the IRS.  S corporation tax history and issues are provided to introduce the subject matter.   A look at six pertinent court cases associated with “tax affecting” are explored including a more detailed look at the most recent court case on this issue.   Five of the most popular models used for “tax affecting” are introduced and discussed.   Given this material the practitioner is asked whether they believe they should make an adjustment for S corporation valuations (“tax affecting”).  If so, how should it be made considering the various risks of this factually intense and well litigated issue.  Finally, Mike presents his personal perspective on the issue and invites attendees to share their views.   

The 52nd Annual Federal Tax Institute sponsored by the Arkansas Society of CPAs and the Arkansas BAR Association
Little Rock, Arkansas