BEST OF THE BEST
HCVT recognized as a Best of the Best Firms for 17 consecutive years and is ranked #31 in the Top 100 firms in the United States.
On August 2, 2016, the IRS issued the long-anticipated proposed regulations under Internal Revenue Code Section 2704. These regulations would close tax loopholes that taxpayers commonly use to take significant discounts for lack of control and lack of marketability when valuing transfers of ownership interests in family-owned business entities such as partnerships, limited liability companies, and corporations.
In general, the proposed regulations provide that when valuing an interest in an entity transferred to a family member, certain restrictions set forth in operating or shareholder agreements must be disregarded. Discounts of 30-40% have previously been applied in valuing these interests, and while not completely eliminated under the proposed regulations, they will be significantly reduced.
Some interesting items to note:
Hearings on the proposed 2704 regulations are scheduled for early December 2016, and when finalized, would likely become effective as early as January 2017. If you are considering doing any gift or estate tax planning involving the transfer of assets that would be the subject of valuation discounts, you should contact us as soon as possible as the time window to implement certain planning ideas will be limited.
HCVT provides tax, accounting, business management, and mergers & acquisition services to private companies, closely-held businesses, public companies and high net worth individuals and family offices. We provide auditing services to privately held businesses, funds, and employee benefit plans. Today, we are a team of over 450 members, 48 partners, and 47 principals. We serve our clients from eight offices in Southern California and offices in Walnut Creek, CA, Ft. Worth, Texas and Park City, Utah. We are highly specialized and focus on specific industries and market niches.
Robin Paule is a tax partner at HCVT and addresses the tax complexities associated with estate and gift tax planning, stock option and retirement planning, business succession planning, planning for sales of businesses, charitable giving strategies, and tax-exempt organizations.
Eniko Early is a tax principal and specializes in investment partnerships, trust analysis, compliance and administration, and estate and gift tax planning and compliance.
To learn more about HCVT, see www.hcvt.com