(Part II of II) There are special tax considerations related to the transfer of S corporation stock at the time of the owner’s death. Therefore, owners of S corporation stock must be intentional with regard to the risks (and the tax costs) associated with an inadvertent termination of the subject entity’s S corporation status. S corporation owners—and analysts—should be aware that many states tax S corporations for state corporation income tax purposes. Many states tax S corporations as if they were C corporations. In addition, many other states apply a special corporate income tax rate to S corporations. The second…
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(Part I of II) Analysts are quick to identify and quantify the implicit and explicit S status economic benefits in the S corporation business valuation. The objective of this discussion is to summarize the offsetting economic risks associated with an S corporation ownership interest. Analysts should be equally aware—and intentionally consider the risks as well as the benefits—of S corporation status in the subject private company or professional practice valuation. This discussion summarizes many of these risk factors that analysts, private company/practice stockholders, and the company/practice professional advisers should consider in the valuation of an S corporation ownership interest. Part…
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And S Corporation Acquisitions Analysts should be aware that one transaction tax structure that is particularly popular regarding private equity firm acquisitions is an Internal Revenue Code Section 368(a)(1)(F) reorganization of the private S corporation. The article discusses several of the reasons why owners may want to sell—and why private equity firms may want to buy—an S corporation target company. The article describes what analysts need to know about the benefits to the S corporation sellers of a Section 368(a)(1)(F) reorganization as one step in the private company sale transaction. In addition, it also describes what analysts need to know…
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On Business Valuations The Tax Cuts and Jobs Act (TCJA) changes many aspects of how business analysts perform valuations. Upon passing of the TCJA, Jim Hitchner moved quickly to gather and disseminate information about the TCJA and its effect on business valuation. He has written two comprehensive articles in Issues 72 and 73 of Financial Valuation and Litigation Expert. The information in this article summarizes some of the main points expressed in those publications.
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The requirements that S corporations must meet may be challenging but any violation of the rules may result in an inadvertent termination of an S corporation’s status. Sally P. Schreiber, senior editor with the AICPA Magazines & Newsletters team, outlines the S corporation requirements and talks about the seven types of trusts that qualify to be S corporation shareholders. She discusses how the IRS is providing limited relief for corporations who violate the rules and making it fairly easy for them to fix these problems. [button color=”blue” link=”http://www.cpa2biz.com/Content/media/PRODUCER_CONTENT/Newsletters/Articles_2015/CorpTax/s-corporation-inadvertent-terminations.jsp” target=”_blank” font=”arial” align=”left”]For more information on ways to avoid S corporation inadvertent…
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Beyond an all-or-nothing approach This overview examines the circumstances under which S corporations may or may not be tax affected. Particular emphasis is placed on family law engagements, which do not always involve a consistently defined standard of value, which creates much confusion for valuation analysts.
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How to apply the landmark cases Delaware MRI (2007) and Bernier (2012) Eric J. Barr, CPA/ABV/CFF, CVA, CFE, analyzes two landmark court decisions—Delaware MRI and Bernier—and offers more clarity on the proper way to value an ownership interest in a pass-through entity under the fair market standard of value.
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Taxes on S-Corporations are Hotly Discussed by Legislators and May Change. Here’s the History, Standing Precedents, and Current Law. S Corporations have been much in the news lately, as we’ve noted on the QuickRead blog. In this piece, Peter Agrapides provides a comprehensive chronological account of valuation cases where the issue of tax affecting S-Corporations has taken center stage.
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All kinds of news, findings, and rulings come out that might affect the work of financial consultants and appraisers every day. When can you know when a precedent is important or something you can ignore? Or, put another way: what information is most important to pay attention to? Rand Curtiss explains.
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Congressional Democrats have proposed financing student-loan legislation by expanding payroll taxes on subchapter S corporations and partnerships. The bill would levy Social Security and Medicare taxes on all business income if the firm is engaged in professional services, such as investment advice, or if 75% or more of the gross income of the firm is attributable to three or fewer shareholders. Investment News’ Mark Schoeff Jr. reports that in Washington parlance, the phrase “pay for” has become a noun, “payfor.” This term trends during the legislative process, as lawmakers seek “payfors” to offset spending or tax cuts contained in bills.…