An independent and well-supported valuation is an important part of tax compliance or a tax-planning strategy.
Marcum assists individuals, corporate clients, tax attorneys, and others with valuation issues related to tax matters.
Estate and Gift Tax Compliance and Planning
Obtaining a reliable third-party opinion of value is an important part of successful estate planning strategy and execution. Following the standards of our profession expected by the IRS, we have successfully documented hundreds of transfers for estate and gift tax compliance purposes.
The valuation of closely held businesses for estate and gift tax purposes is a specialty within the business valuation arena. It requires in-depth knowledge of the fair market value standard, understanding of the Special Valuation Rules of Chapter 14 of the Internal Revenue Code, analysis of the subject entity’s corporate documents and the rights and restrictions of the interest being valued, and knowledge of the empirical data available to support valuation discounts. We are well-versed in these topics, as well as in complex emerging issues, including tiered-entity discounts and formula clauses.
Corporate Reorganizations
Marcum has deep expertise in advising our corporate clients and their tax counsel on valuation issues in domestic and cross-border tax reorganizations.
Our services include:
- Valuations of business and legal entities.
- Valuations of intangible assets.
- Debt restructuring/forgiveness.
Discount Studies for Estate Planning Vehicles and Investments Subject to Lock-Ups
Valuation considerations for popular estate planning vehicles, such as family limited partnerships ("FLPs") and family limited liability companies ("FLLCs"), are constantly evolving. Tax court cases continue to influence many issues that affect the already complex terms of these entities’ agreements, and the effect that the ever-increasing complexity has on valuation of interests in FLPs and FLLCs. Having performed numerous valuations of FLPs and FLLCs, as well as having successfully defended our valuations before the IRS, we bring a deep understanding of the issues that affect the valuation of the interests in these entities.
We leverage our expertise in alternative asset classes, such as hedge funds and private equity, to offer an insight into an impact of the fund- and the investor-level lock-ups, gates, and other restrictions; and on the discounts that may be applicable to the interests in the pooled investment vehicles that invest in alternative asset classes or strategies. We are routinely sought out by wealth management advisors, hedge fund managers, investors, attorneys, and other parties to model the impact of these restrictions and to advise on a magnitude of the discounts.
Issues Related to Valuation of "S" Corporations and Other Pass-Through Entities
The valuation of Subchapter S Corporations and other pass-through entities is one of the most controversial issues in business valuation today. Members of our staff are nationally known experts, having been in the forefront of the discussion on this important topic.
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New Haven, CT
CT