Last week, we considered (i) the context in which the recently proposed regulations under Section 2704 of the Code would eventually be applied, (ii) the principles underlying Section 2704, (iii) the valuation of an interest in a closely-held business, generally, and (iv) the failed legislative efforts to address the issues covered by the proposed
Section 2704
The IRS Takes The Offensive On Valuation Discounts: Part Two
By Farrell Fritz P.C. on
Posted in Federal Tax Issues
In yesterday’s post, we considered the context in which the recently proposed regulations under Section 2704 of the Code will eventually be applied. Today, we will discuss Section 2704 and the valuation of an interest in a closely-held business. We will also review the failed legislative efforts to address the issues covered by the…
The IRS Takes The Offensive On Valuation Discounts: Part One
By Farrell Fritz P.C. on
Posted in Federal Tax Issues
“The” Proposed Regulations
They were years in the making – proposed regulations that seek to address what the IRS believes are abuses in the valuation of family-owned business and investment entities. Based upon the volume of commentary generated in response to the proposed rules, it is clear that the IRS has struck the proverbial raw…