The Ongoing Research and Analysis Relating to the S Corporation Valuation Puzzle What premium, if any, should S Corporations command? How reliable are the current models? How reliable is the evidence that supports the position of the leading U.S. Tax Court cases? What should valuation analysts and consultants consider as they advise newly formed corporations considering making the S election and S corporation shareholders that are about to discuss buy-sell agreements? In this book, Fannon and Sellers critique existing theory and practice and propose a new model to value S corporations.
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Background and Objectives of the Job Aid (Part 3 of 3) In the third article of this three part series, the author discusses the remaining portions of the Job Aid, specifically, the Discussion and Analysis Section of the Job Aid which addresses: Evidence-Based Valuation Analysis, Theory-Based Valuation Analysis, and Weighting of Factors and Approaches and shares his views on the value and limits of this document. Read Part 1 and Part 2.
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Background and Objectives of the Job Aid (Part 2 of 3) In the first of this three-part series, the leading cases involving tax-affecting where analyzed; those cases discussed included: Gross, Wall, Heck, Adams, Dallas, Gallagher, Korbel, and Guistina. This second part analyzes the first two parts of the Job Aid by section, the “Executive Summary” and first three subsections of the “Discussion and Analysis”, ending with “Additional Factors for Consideration”.
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Background and Objectives of the Job Aid (Part 1 of 3) The release of this series of Job Aids has been hailed by many as a new era of communication and understanding between the Internal Revenue Service, taxpayers, and practitioners. However, in the opinion of this author, and others, releasing these additional documents in such a formal manner seems to be an attempt to influence practitioner behaviors in specific practice areas without statutory support. As was the case with the earlier Job Aid on Discounts for Lack of Marketability, the newest Job Aid contains little new information. Predictably, the position…
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With Commentary by Original IRS Champion Leading valuation practitioners have proposed various models to guide practitioners valuing controlling and non-controlling interests. The published Tax Court cases—precedents—have favored the position of the IRS. The author suggests that is not surprising. In a soon-to-be released book, Michael Gregory highlights the importance of a new Job Aid focused on valuation of S corporations.