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Understanding "Tax-Affecting" and Other Critical Valuation Issues Impacting Pass-Through Entities after Estate of Aaron Jones v Commissioner



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Recording and Slides are Available Here


In their exclusive LISI Webinar, Steve Gorin, Scott Miller and Curtis Kimball from Willamette Management Associates, the valuation firm whose testimony generated the first significant taxpayer victory in US Tax Court on ""tax affecting"" in Estate of Aaron Jones v Commissioner, will discuss valuing interests in partnerships and S corporations.  


After watching their webinar, you will learn:
 
  • What ""tax-affecting"" is and why it's important; 
  • How the appraiser in Estate of Aaron Jones persuaded the court to accept tax-affecting for the first time; 
  • Issues to consider in building a case for tax-affecting; 
  • Other issues appraisers consider in valuing interests in partnerships and S corporations


There will be no CE for this webinar


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Scott Miller is a vice president with Willamette Management Associates. Scott has performed the following types of valuation and economic analysis assignments: merger and acquisition valuations, business and stock valuations, divestiture and spin-off valuations, fairness opinions, forensic analyses, transfer pricing analyses, property tax valuations, estate tax valuations, ad valorem property tax valuations, intangible asset and intellectual property valuations, marital dissolution valuations, lost profits/economic damages analyses, and appraisal reviews. He has prepared these valuation and economic analyses for the following purposes: transaction pricing and structuring, taxation planning and compliance (federal income, gift, and estate tax; state and local property tax; transfer tax), forensic analysis and dispute resolution, and strategic information and planning. Scott has estimated the value, remaining useful life, and/or license/royalty rate of the following types of intangible assets: customer-related intangible assets, goodwill, and trademarks and trade names. Scott has valued the following types of business entities and securities: closely held corporation business enterprises, closely held corporation noncontrolling ownership interests, various classes of common/preferred stock, public corporation subsidiaries/divisions, general and limited partnership interests, professional service corporations, professional practices, and LLCs. Scott has performed business, stock, and intangible asset valuations for clients in the following industries: accounting and consulting, apparel, architecture, biotechnology, cement, chemical, communications, construction and contracting, grocery stores, high-tech, education, equipment leasing, financial services, food processing, food service, forest products, health care, information technology consulting, insurance, leasing, manufacturing, medical practice, printing, natural resources, public utilities, real estate development, restaurant services, retailing, software, staffing services, telecommunications, and wholesaling.

Curtis Kimball is a managing director of Willamette Management Associates. In addition to his work on all types of valuation engagements for the firm, Curtis is also the firm's national director of wealth management valuation services.Curtis supervises engagements related to the valuation of business entities and business interests, the analysis of publicly traded and private securities, and the valuation of intangible assets, options and derivative interests, claims, fractional interests, and intellectual property. He has performed the following types of valuation assignments: estate and gift planning valuations, estate tax (both date of death and alternate value date) valuations, gift tax valuations, generation-skipping tax valuations, fiduciary compensation and damages claims valuations, buy-sell agreement valuations, income tax valuations (including charitable deduction, transfer pricing, intangible asset basis, and loss deduction), expatriation tax valuations, fair value valuations for financial reporting purposes, merger and acquisition valuations, fairness opinions, solvency analyses, ESOP feasibility and initial transaction valuations, ESOP employer stock valuations and transaction fairness valuations, insurance valuations, divorce and equitable division valuations, various forensic analyses, fair value in dissenting shareholder rights and shareholder oppression proceedings, economic damages and lost profits analyses, bankruptcy and restructuring analysis and valuations, employee compensation and stock option valuations, and financing collateral valuations. Curtis has presented expert testimony in federal courts (U.S. Tax Court, U.S. District Court, U.S. Court of Federal Claims, and U.S. Bankruptcy Court), various state courts, and in alternate dispute resolution venues including binding arbitration and mediation. Curtis acts as the firm's national director for wealth management matters (including estate, gift, charitable, fiduciary, marital planning, family and partner disputes, and tax issues for high net worth families and their businesses). He has extensive experience with appearances in IRS audits and appellate conferences. Curtis has decades of experience in the valuation of various types of business entities and interests, including: private family-owned businesses, private multiple-investor businesses, employee-owned businesses, minority interests, 50 percent interests, restricted stock of publicly traded companies, large blocks of publicly traded securities, preferred stock interests, multiple classes of preferred and common stock in complex capital structures, secured notes, subordinated debt interests, options and other derivative interests, warrants and rights offerings, general and limited partnership interests, limited liability company membership interests, professional practices, joint ventures, licensing agreements, franchises, and foreign-domiciled corporations. In addition, his experience includes the valuation of various types of intangible assets, claims, damages, and intellectual properties. These include: patents, copyrights, trade secrets, master recordings, programming libraries, core deposits, customer contracts, franchises (including professional sports franchises), product licensing, management employment contracts, fiduciary damages and claims, noncompete and nonsolicitation agreements, customer lists, cutting and hunting rights, undivided fractional interests in real estate, assembled workforces, trademarks/trade names/trade dress, contract rights, breach of contract damages, going-concern values, goodwill, and transfer price agreements. Curtis is an Accredited Senior Appraiser (ASA) of the American Society of Appraisers in business valuation. He served as a member and the Treasurer of ASA's Business Valuation Committee, as a member of the ASA's International Ethics Committee, its Investment Policy Committee, and its International Board of Examiners. He is currently a member of the ASA's Business Valuation Standards Sub-Committee. He has served as president, secretary, and treasurer of the Atlanta Chapter of the ASA. He is the past chair of the Atlanta Chapter's Business Valuation Committee. He has served as Treasurer of the Portland Chapter of the ASA . He is also a Chartered Financial Analyst (CFA) of the CFA Institute (CFA-I). He was a member of CFA-I's Board of Examiners and was a senior grader for the examinations leading to the CFA designation. Curtis served as a member of the Disciplinary Review Committee of CFAI and served as a member of the disciplinary/ethics hearing panelist pool. He was a member of the Portland Society of Financial Analysts (a CFA-I local chapter), for which he served as secretary and a member of the board of directors. He also served as a member of the board of trustees of the Atlanta Society of Financial and Investment Professionals (a CFA-I local chapter) and served as its Membership Chair. He is also a member of the ESOP Association, the Institute of Management Accountants, the National Association of Corporate Directors, and the National Association of Business Economists, for which he was a past president of the Portland chapter and treasurer of the Atlanta chapter.


Steve is a nationally recognized practitioner in the areas of estate planning and the structuring of privately held businesses. Lawyers, accountants and business owners regularly look to Steve for fresh, highly knowledgeable insights into the best possible tax and estate planning approaches to their transactions.

Steve crafts estate plans for individuals, keeping in mind their financial security and desire to save income and estate tax. In his work for businesses, Steve helps owners plan for the eventual sale (to co-owners, employees, or third parties)or transfer (to family members), and provides a legal framework for an orderly transition while strategically saving income, transfer, and FICA taxes.

Drawing on his background as an accountant — and his still-current CPA license and Chartered Global Management Accountant credential — Steve structures businesses to achieve business objectives and save income or estate tax. He has helped fledgling businesses organize, thriving businesses restructure to save hundreds of thousands of dollars of income tax when planning a transition to the next ownership group, and mature multi-million or billion-dollar businesses plan tax-saving transfers to the next generation.

Over the course of his 30-year career, Steve has amassed a deep knowledge of nearly every aspect of tax strategy for privately held businesses and freely shares that knowledge with others in the field. His quarterly newsletter, Business Succession Solutions," is considered essential reading for hundreds of CPAs and attorneys, who describe it as "a fantastic contribution to the field." Steve also maintains a blog, Business Succession Solutions, intended to help business owners — and those who advise or support them — consider smart tax strategies.

Steve is a highly visible member of the ABA's Real Property, Trust & Estate Law Section and the American College of Trust & Estate Counsel, which regularly directs its members to Steve's quarterly newsletter. He has represented both groups in comments to the IRS, the U.S. Treasury, and tax lawmakers.


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