Allocation Rules for Asset Transactions
In an asset sale transaction, the allocation of the aggregate purchase price among the target’s assets is of great importance for both the buyer and seller, and often leads to renewed negotiations after an initial deal has been struck...

Preparing For Sale: Get Ready for a Potential Buyer to Kick the Tires
As we discussed in a previous issue of For What Its Worth, there are several ways to transfer an ownership interest. For those business owners who desire to transfer ownership through a negotiated sale, it is important to address several issues as a first step in the sale process. By anticipating a potential buyer’s questions and concerns surrounding these critical issues...

Preserving Family Limited Partnership Valuation Discounts
The IRS continues to challenge valuation discounts for estate and gift tax purposes on transfers of interests to family limited partnerships (FLP). In 2005 the IRS won several cases based on IRC Sec. 2036 challenges. Under Sec. 2036(a) assets transferred during the decedent’s life will be included in the decedent’s gross estate if the assets are transferred by means other than sale...

The State of the Estate Tax and Its Impact on Estate Planning
Despite the statistic that only about 2 percent of estates pay estate taxes, the estate tax brings in around $70 billion a year in tax revenues. If repealed, some say the total loss of revenue over a 10 year period would exceed $700 billion plus interest. Yet, many Republicans are still pushing for a full repeal of the estate tax and will lobby Democratic senators strongly until a Senate vote...

FWIW - Fall 2005/Winter 2006

FWIW is intended to inform readers of developments in the field of valuation. The articles written may, or may not, reflect the opinion of the authors. Please note, any advice contained in this publication was not intended, or written, to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. This publication is distributed with the understanding that the publisher and distributor are not providing legal, accounting or other professional advice and assume no liability whatsoever in conjunction with the information contained within this publication.