Valuation is a core concept in taxation, with the hypothetical party FMV standard of value well-established. However, the subjectivity surrounding this standard of value requires careful planning and implementation of transactions that have valuation discounts as one of their goals. Since family transactions are the subject of close scrutiny by IRS and the courts, careful planning here involves a true understanding of the concept of value and how to support and defend value conclusions.
With over 75 pages of course materials and discussion of multiple valuation case studies, course participants will be provided with insights in 'playing the valuation game.' This course reviews a number of special valuation rules, including the AFR minimum interest rule of IRC Sec. 7872 and the Chapter 14 provisions which are IRC Secs. 2701-2704, inclusive. Also, possible legislation on valuation issues will be considered and IRS audit strategies reviewed.
Upon successful completion of this course, participants will be able to:
- Identify the objectives of transfer tax planning and the process involved in implementing those objectives.
- Cite relevant details and factors that can influence valuations.
- Recognize court cases to identify key valuation issues that can be applied to client situations.
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