| 1 | 3/25/2009 | BVResearch |
Commissioner v. Estate of Jelke: Briefs on Writ of Certiorari to the U.S. Supreme Court (2008)
Commissioner v. Estate of Jelke: Briefs on Writ of Certiorari to the U.S. Supreme Court (2008...
Articles
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| 2 | 2/1/2003 | BVResearch |
C Corporations with Appreciated Assets: Valuation Discount for Built-In Capital Gains
The valuation of a C corporation is a common valuation assign-ment. Experienced analysts routinely value 100 percent of the stock of a C corporation for such purposes as: merger and acquisition pricing; estate and gift tax planning and compli-REVIEW OF...
Jacob Roosma
Willamette Insights (4,630 words)
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| 3 | 5/5/1997 | BVResearch |
The Art of Making Uncle Sam Your Assignee Instead of Your Senior Partner: The Use of Family Partnerships in Estate Planning(s)
THE ART OF MAKING UNCLE SAM YOUR ASSIGNEE INSTEAD OF YOUR SENIOR PARTNER: THE USE OF FAMILY PARTNERSHIPS IN ESTATE PLANNING(c) By S. Stacy Eastland I. SYNOPSIS OF OUTLINE The primary purpose of...
Stacy S Eastland
Articles (70,992 words)
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| 4 | 4/28/2008 | BVResearch |
The Jelke Reversal
The Jelke Reversal Teleconference Presentation and Transcript January 17th, 2008 Moderator: Lucretia Lyons Panelists: John W. Porter, Partner at Baker Botts, L.L.P. William H. Frazier, Partner at Howard Frazier Barker Elliott, In...
Teleconference Transcripts (14,681 words)
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| 5 | 3/20/2006 | BVResearch |
How to Discount for Trapped-In Capital Gains Tax
August 2004 Teleconference Transcript; Panel: Shannon Pratt (Moderator), William Frazier, Mark Lee, and Eric Nath...
Teleconference Transcripts (14,098 words)
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| 6 | 11/1/2003 | BVResearch |
The Treatment of the Built-In Capital Gains Tax Liability
A valuation analyst should consider many different issues when performing a valuation of a closely held company for gift or estate tax purposes. One issue that has gained both notoriety and importance among valuation practitioners is the question of how...
Paul Carlin
Willamette Insights (2,295 words)
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| 7 | 2/1/2006 | BVResearch |
The 'BIG' Tax Discount in Asset-Based Business/Stock Valuations for Estate Planning/Estate Tax Purposes
tion by reference to (1) the current value of all its assets When the stock of a closely held business is an asset in (both tangible and intangible) less (2) the current value the deceased's estate, the valuation of the business/stock of all of its li...
James Rabe
Willamette Insights (3,992 words)
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| 8 | 9/11/2008 | BVResearch |
Jelke and the Liquidation Scenario Paradox
Relying heavily on the Fifth Circuit's decision in Dunn,1 the Eleventh Circuit's decision in Jelke2 adds significant weight to the argument that the law of the land, when valuing a Corporation by the asset approach, now permits the deductibility in ful...
Articles (4,700 words)
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| 8 | 5/1/2003 | BVResearch |
Business Valuation Discount Related to the Built-In Gains (BIG) Tax Liability
ence to (1) the current value of all its assets (both tangible andThe valuation of the stock of a closely held business is an inte-intangible) less (2) the current value of all of its liabilities (bothgral component of the formation, financing, contribu...
Robert F Reilly, Susan Gould
Willamette Insights (4,596 words)
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| 10 | 5/7/1999 | BVResearch |
Expert Dubbed -- "Unpersuasive" Rebuts Judge Laro's Rejection
May 7, 1999 Re: Kaufman Case Dear Shannon: I enjoyed speaking with you on the telephone and I appreciate your taking the time to review the Kaufman case. I have enclosed copies of the case, m...
Bret A Tack
Articles (3,550 words)
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| 11 | 6/11/2008 | BVResearch |
Using the BPM Total Cost of Equity (TCOE) and Public Company Specific Risk Calculator
In this webinar, Keith Pinkerton and Pete Butler help the listener understand the theory, assumptions and key conclusions behind the BPM, how to analyze the inputs and outputs to the Calculator, and they illustrate practical applications of the BPM to pro...
Teleconference Transcripts (16,302 words)
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| 12 | 7/15/2007 | BVResearch |
Developing Discount Rates in a Global Environment
The role of the valuation consultant is to communicate supportable findings, taking into consideration the wide variety of market data, academic writings, and market participant views. Country risk adjustment is not just for war or expropriation but...
James T Budyak
CICBV Publications (16,762 words)
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| 13 | 5/1/2004 | BVResearch |
Adjustments May Be Necessary When Centrally Assessed Values Are Based on Capital Market-Derived Data
When capital market-derived data (e.g., security prices, price/earnings pricing multiples, and earnings/price capitaliza-tion rates) are used in market and income approach methods to unit valuation, valuation adjustments may be applicable. These valuati...
Pamela Garland
Willamette Insights (3,513 words)
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| 13 | 8/1/2003 | BVResearch |
Long-Term Executive Compensation Plans in Privately-Held Companies
The reasonableness of executive compensation is a sensitive topic for any company. For privately held or family-owned companies, the topic can be particularly sensitive. This is because management employees often fulfill multiple functions. Company execut...
Susan Gould
Willamette Insights
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| 13 | 11/17/1997 | BVResearch |
Recognizing Built-in Capital Gains for Valuation Purposes
Click here for full text of paper.
Roger Lusby
Presentations (3,539 words)
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| 16 | 7/1/2005 | BVResearch |
Embedded Capital Gains, One More Time: Estate of Jelke v. Commissioner
There were three valuation issues before the Court in Estate of Jelke v. Commissioner (T.C. Memo 2005-131, filed May 31, 2005 ). 1. What is the appropriate treatment of the embedded capital gains tax liability within Commercial Chemical Company ("CCC...
Mercer Capital’s Value Matters (3,414 words)
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| 16 | 6/22/2001 | BVResearch |
Imbedded Income Taxes - Built-In Gains Taxes: Business Valuation Considerations
Built-In Gains Taxes: Business Valuation Considerations I. Introduction Generally, valuations pursuant to the market approach and income approach relate to operating businesses. These valuat...
Leonard J Sliwoski
Presentations (5,365 words)
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| 16 | 1/8/2000 | BVResearch |
Valuations That Will Withstand Current Challenges (and Those That Won't)
VALUATIONS THAT WILL WITHSTAND CURRENT CHALLENGES (AND THOSE THAT WON'T) Shannon P. Pratt, CFA, FASA, CBA Managing Director Willamette M...
Shannon P Pratt
Presentations (4,735 words)
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| 19 | 3/21/2006 | BVResearch |
Transaction Method of Valuing a Business
October 2004 Teleconference Transcript; Panel: Shannon Pratt (Moderator), Rand Curtiss, Thomas Pastore, and Jack Sanders...
Teleconference Transcripts (16,417 words)
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| 20 | 6/17/2009 | BVResearch |
Estate of Litchfield v. Commissioner
Tax Court considers determination of discounts for embedded capital gains taxes, lack of control, and lack of marketability for estate’s interests in two closely held companies, one owning primarily farm land and the other marketable securities.
Court Case Abstracts (2,289 words)
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