Topic
Built-In Gains
8 published works
Larry's Tax Law
A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part 1 – The Built-In-Gains Tax
By Larry Brant
In October 2023, I authored a new White Paper, A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The…
Agricultural Law and Taxation Blog
Is A Discount For The BIG Tax Available?
OverviewThrough 2016, the U.S. Treasury Department was pushing for the elimination of valuation discounts for federal estate and gift tax purposes. However, as part of the elimination of “non-essential” regulations…
Wealth Director
The Three Most Important Provisions for S Corporations Under PATH Act
It has become a tradition that at the end of each year, Congress passes legislation to extend previous legislation. In late 2015, Congress passed Public Law 114-113, which contains the…
Tax Law for the Closely Held Business
House Ways & Means Committee Makes a BIG Move
We have previously looked at the recognition period for built-in gains of S corporations, and the effect of the expiration of the temporary reduction of this period, under the American…
Tax Law for the Closely Held Business
S Corp Sales, Built-In Gain, and 2013
By Lou Vlahos
Last year saw many taxpayers selling appreciated assets. The primary reason for this activity was the imminent increase, in 2013, of the long term capital gain rate, and the imposition…
New York Business Divorce
Ruling on Valuation Discounts for Marketability, Built-In Gains Tax Ends Rift Among New York Appellate Courts
The Appellate Division, Second Department last week affirmed the key rulings by Justice Ira Warshawsky in the Murphy v. U.S. Dredging valuation case, including his application of a marketability discount…
New York Business Divorce
Dissenting Shareholder Stock Appraisal Triggered by Freeze-Out Merger Raises Issue of Post-Merger Tax Consequences for C Corporation with Built-In Gains
Stock valuation junkies can get their fix in this week's New York Business Divorce, as it revisits the issue of discounts for BIG -- as in built-in capital gains taxes…
New York Business Divorce
Court Discounts Fair Value Award for Built-In Gains Tax in Shareholder Oppression Case
Justice Ira Warshawsky of Nassau County Supreme Court's Commercial Division has issued a "BIG" decision (as in discount for Built-In Gains tax) in a stock valuation arising out of a…