Uncategorized
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Case Highlights: Estate of Aaron U. Jones v. Commissioner, T.C. Memo. 2019-101
- September 6, 2019
- Category: Uncategorized
By David Rudman, CPA/ABV, CVA – Sigma Valuation Consulting, Inc. Synopsis In May 2009, Aaron Jones gifted his interests in an S corporation and limited partnership that together owned a lumber and timber business to his three daughters and to his family trusts for their benefit. In his gift tax return, he reported the gifts
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AICPA Adequate Disclosure Reference for 2016 Gifts Made After Issuance of the Proposed Section 2704 Regulations
- January 26, 2017
- Category: Uncategorized
AICPA Suggested Disclosure Statement For 2016 Gift Tax Returns Reporting Transfers of Interests in Family Controlled Entities, Include Adequate Disclosure Reference for the Section 2704 Proposed Regulations Under the adequate disclosure rules, if a position taken on a gift tax return is contrary to a proposed regulation, it must be disclosed in order for the
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Common Errors in the Valuation of Carried Interests and Fund Management Structures
- December 2, 2016
- Category: Commercial & Shareholder Litigation, Corporate Advisory & Tax Compliance, Estate & Gift Valuation, Matrimonial Valuation & Litigation Support, Uncategorized
By David Rudman, CPA/ABV, CVA – Sigma Valuation Consulting, Inc. As you may recall in my prior article published in the American Bar Association’s eReport to its Trust & Estates and Real Property Sections titled, “A Primer on the Valuation of Hedge Fund and Private Equity Fund Management Interests,” we noted that General Partners or
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Extended Thoughts on the IRC 2704 Proposed Regulations
- August 5, 2016
- Category: Corporate Advisory & Tax Compliance, Estate & Gift Valuation, Uncategorized
By Matthew E. Rappaport, Esq. LL.M – Tax Planning & Structuring Attorney In the wake of the Internal Revenue Service releasing Proposed Regulations pertaining to IRC 2704 yesterday, I have received many questions and conducted many discussions about the Proposed Regulations’ content and potential impact. I posted a short status update about my preliminary thoughts