Cover Story
Contingent assets and liabilities present a number of unique and complex issues for companies, individual taxpayers, and their advisors. Recent court cases and the finalized Treasury Regulations have provided a certain level of guidance to trust and estate attorneys. This article addresses the implications of the Treasury Regulations, the facts and circumstances surrounding those instances in which the recognition and valuation of contingent assets and liabilities is required, and the various valuation methodologies to be considered in doing so.
FEATURED ARTICLES
Over the years, the Internal Revenue Service appears to have increased both their valuation expertise as well as the aggressiveness of their positions. This interview with Daniel R. Van Vleet, ASA, explores the challenges of working with the IRS in estate and gift tax controversies.
For executives with companies contemplating an IPO or that are in the process of going public, it is typically not too late to consider various estate tax planning initiatives. Until the company actually begins to trade on a public exchange, its value as a private company is still likely lower than its expected value after the IPO for various reasons. The lower value and uncertainty of going public creates opportunities to gift interests at discounts relative to the future IPO price.
Trusted advisors frequently become embroiled in divorce disputes among their high net worth clients. This article summarizes a number of issues, which such advisors should impart to a client heading for divorce.
