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Multi-National Companies Face Tax Risk with Transfer Pricing

Because of increased IRS audit procedures, multi-national corporations face great risk when it comes to transfer pricing from both a compliance and tax planning perspective.  The familiar multi-nationals like Amazon or Microsoft have made headlines regarding transfer pricing disputes and adjustments that run into the billions.  In an excellent article by the Journal of Accountancy, small, closely-held compa ...

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IRS Loses in E&G Tax Case

The Tax Court recently denied an IRS motion for summary judgment in an estate and gift tax case where an elderly mother made gifts to her daughters, while requiring them to pay all tax liabilities due if she happened to die within three years of making the gifts.  In the calculation for gift tax purposes, the mother reduced the value of the gifts by the estimated tax liability.  This reduction was denied by ...

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Estate & Gift Tax Update

In the first installment of a two-part series, the AICPA reviews the most important developments affecting estate, gift and generation-skipping transfer (GST) tax and trust income tax over the last 12 months.  In the period from June 2012 through May 2013, the analysis covers legislative developments, rulings, pending cases, the American Taxpayer Relief Act of 2012 and inflation adjustments for 2013.  The s ...

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Making Sense of the Blockage Discount: It’s Much More Than Simple.

Giving holders of concentrated risk in public company stock a tax break This article establishes there is recognition by the IRS and the courts that a well-supported proof of impairment based on the sale of a large number of shares necessitates an investor concession. It provides the rationale and methodology to capture the existence and the level of impairment. ...

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Minnesota Twins Ownership Tangled in IRS Estate Tax Debate

In early 2009, Carl Pohlad, investor and principle owner of the Minnesota Twins, passed away, leaving controlling ownership of the team to his sons.  In settling the estate, the new owners now find themselves embroiled in a tax tangle with the IRS.  The primary point of contention exists with what Pohlad’s share in the team was actually worth at the time of death.  According to the IRS, Pohlad’s ownership i ...

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IRS Resists Negotiation on Penalties—Appraiser News Online, Bloomberg BNA

If IRS Imposes a Penalty, That Penalty Cannot be Negotiated as Part of a Settlement on Another Tax Matter  The Internal Revenue Service is opposed to negotiating penalties with noncompliant taxpayers, a stance that should benefit appraisers and tax advisors because individuals will be required to assume more responsibility for their deductions, Bloomberg BNA (subscription required) reported this month.   Ap ...

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Kite v. Commissioner is a Major Loss for IRS —Financial Planning

Case Involved $6M in Gift Tax and $5M in Estate Tax; Interest in General Partnership Sold for Private Annuity; Much Planning at the End of 2012 Bruce Givner at Financial Planning reports that U.S. Tax Court Judge Elizabeth Paris handed the taxpayers a victory last Thursday [2/14/2013]  involving a powerful estate tax planning tool: private annuities.   The case, Estate of Kite v. Commissioner, is important, ...

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IRS Wins Major Tax Shelter Case —WSJ Washington Wire

Tax Court Judges Structured Trust Advantaged Repackaged Securities” ("STARS") as Illegitimate.  Costs to BNY/Mellon May Exceed $800M. The Internal Revenue Service won a high-profile tax shelter case involving Bank of New York Mellon Corp. on Monday, in a ruling that could cost the company more than $800 million.  John D. McKinnon at the WSJ Washington Wire reports the news: ...

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How IRS Taypayer Advocate Can Help CPAs’ Clients —Journal of Accountancy

The IRS Has a Nationwide Organization of Approximately 2,000 Taxpayer Advocates to Help U.S. Individual and Business Taxpayers Resolve Problems.   Here's How It Can Help Advisors and Your Clients.  Nina E. Olson is the IRS’s National Taxpayer Advocate. Since 2001, she has led the Taxpayer Advocate Service (TAS), a nationwide organization of approximately 2,000 taxpayer advocates who help U.S. individual and ...

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Do You Know What Your Business Is Worth? You Should. —New York Times

Few Business Owners Seem to Even Know How to Make a Good Guess at What Their Business is Worth.  NY Times Introduces Technology to Help—and Certified Advisers Provide Extra Value.  Mark Cohen, at The New York Times Small Business Guide, reports:  "At 53, Joe Ritz is old enough to remember a time when many of the classic cars that now pull into his specialized repair shop were new. “It’s one field where it p ...

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Opinion: Where Revenue Ruling 59-60 Got it Wrong —BVWire News

A Valuation Principal Takes Issue With Revenue Ruling 59-60:  "Does Analysis of Macroeconomic Conditions Add Credibility to My Opinion of  Privately Owned Company Value In My Region?" Rick Warner, ASA, AVA, Principal, Great Lakes Valuations writes that "Most of us as appraisers are familiar with Revenue Ruling 59-60 and its prescription for factors to be considered as part of the valuation of the stock of c ...

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Deloitte: Hedge Funds Meet to Assess New Pressures in the Year Ahead —CFO Journal

Stakeholders Discuss Greater Institutional Investor Makeup, Governance Structures, Greater Regulatory Scrutiny Deloitte Insights contributes a piece to the CFO Journal on the Wall Street Journal site, part of a series designed to provide financial executives a customized resource to help them address the strategic, operational and regulatory issues they face in managing their finance organizations and caree ...

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IRS: Cheapest Obamacare Plan Will Be $20,000 Per Family —IRS Report, HuffPo, Catholic News, Yahoo! Answers, Economonitor. JofA Explains Details.

Details Found in IRS Explanation Issued Wednesday; $20,000 Figure Based on a Family of Four.   In a final regulation issued Wednesday, January 30, 2013, the Internal Revenue Service (IRS) assumed that under Obamacare the cheapest health insurance plan available in 2016 for a family will cost $20,000 for the year.   Under Obamacare, Americans will be required to buy health insurance or pay a penalty to the I ...

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“Linked Out”: A Response to a Business Valuation Standards Discussion

There Are Different Standards. They Have Different Places in Various Appraisals. Here’s Why. Jim Hitchner considers various responses to the query:  “When valuing an operating company, is it necessary to mention USPAP in addition to SSVS 1 when talking about the standards adhered to?”  Good question. There were lots of answers from various valuators in a recent discussion.  Here’s Jim’s take on it all. ...

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Avoiding Last-Minute Errors — Before the Last Minute! — Wall Street Journal Tax Blog

The Wall Street Journal Recounts What the IRS Advises:  Moves to Make as April Grows Near April deadlines may not be that far way,  but some Americans still haven’t even rounded up their W2s, the Wall Street Journal noted in a (just-before-deadline) filing last year.   Acknowledging the tax procrastination is a national pastime, the Internal Revenue Service issued some tips and a series of videos to help la ...

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Estate of Gallagher Tax Court Case is a Valuation Tutorial

The Tax Court Speaks Loudly and Firmly on the Responsibilities of Business Appraisers Hempstead & Co. has published "Estate of Gallagher is a Valuation Tutorial."  The article emphasizes the importance of providing the court with a clear and convincing explanation of the assumptions and arguments you have employed in carrying out a business appraisal. It discusses the recent Tax Court Memorandum opinion ...

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“Health Scare for Small Businesses” — WSJ Law Blog — Growing Trend — Stories in NYT, Economist, WaPo, CNN, Forbes, US News & World Report, The Hill, & More.

Ahead of the new health-care law, small firms worry about crossing the crucial 50-person threshold — and about rising premium rates  Emily Maltby at the WSJ Law blog reports on increasing concerns about the forthcoming healthcare laws among small business owners.  This seems to be a prominent issue and concern among small business owners, and has been noted in most every major media outlet in recent weeks, ...

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Afraid of Being Sued? 4 Ways to Keep Lawyers at Bay —Inc.com

Here are four surprising ways to protect yourself in a law suit and keep legal fees to a minimum. Kevin Daum at Inc. advises:  "Shakespeare said, "First kill all the lawyers." Maybe this seems a tad aggressive, but then again, for most people the last thing you look forward to is someone showing up at your door with a subpoena. Whether a lawsuit is business related or personal, the thought of engaging an at ...

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