Willamette Perspectives

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April 2024

Editors for this issue: Nathan P. Novak, Director of our Chicago office and Timothy J. Meinhart, Managing Director of our Chicago office.

Control Considerations in the Valuation of a 50 Percent Ownership Interest

Chad M. Kirkland

In valuations developed for gift tax, estate tax, and generation-skipping tax purposes or income tax purposes, valuation analysts may be asked to determine the fair market value of a 50 percent interest in a private company. The issues to consider and analyze in selecting appropriate valuation adjustments to apply in the valuation of a 50 percent interest often are unique compared with the issues in the valuation of a less than 50 percent interest (e.g., a 48 percent interest) or a more than 50 percent interest (e.g., a 52 percent interest or a 100 percent interest).

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The Expatriation Tax: How to Present Assets to the IRS When You Say Goodbye to the United States

Samuel S. Nicholls

Longtime U.S. residents who wish to leave the country as a permanent resident might be subject to the expatriation tax. There are important considerations regarding the valuation of assets that are reported to the Internal Revenue Service (“IRS”). The value of those assets affects the level of tax that is paid. In addition to retaining appropriate legal and tax counsel, for certain types of assets – stock or limited partnership interests, real property, and fine art and gems – enlisting the services of a credentialed appraiser, otherwise known as a valuation analyst, may be advisable for reporting the assets’ estimated value on IRS Form 8854.

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The Valuation of Controlling Ownership Interests in the Context of Gift Tax Planning

Timothy J. Meinhart

The increase in the federal lifetime gift and estate tax exemption amount that resulted from the Tax Cuts and Jobs Act of 2017 provides for unique wealth planning opportunities. Many of these opportunities involve the transfer of noncontrolling and controlling ownership interests in privately held operating business entities. The valuation of a controlling ownership interest in a business entity for transfer tax purposes may involve the application of a control premium. The selection and application of a control premium can have a significant effect on the concluded value of the transferred business interest. This article discusses the application of a control premium in the valuation process and the guidance that is available to assist the valuation analyst in properly quantifying the control premium.

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Willamette Insights and Perspectives Back Issues

January Perspectives

Editors for this issue: Justin M. Nielsen and Lisa H. Tran

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October 2023 Perspectives

Editor for this issue: Weston C. Kirk

October 2023 Perspectives Cover

July 2023 Perspectives

Editor for this issue: Timothy J. Meinhart

July 2023 Perspectives Cover

April 2023 Perspectives

Editor for this issue: Charles Wilhoite and Scott Miller

April Perspectives cover

Winter 2023: Best Practices

Editor for this issue: Robert F. Reilly, CPA

Willamette Management Advisors Winter 2023 Insights

Transfer Tax Valuation Thought Leadership

Damages Measurement Thought Leadership

Property Appraisal Thought Leadership

Fair Value Measurement Thought Leadership

Valuation, Damages, and Transfer Price Thought Leadership

Reasonableness of Compensation Analysis Thought Leadership

Autumn 2022: Thought Leadership in Wealth Transfer Valuation Issues

Editor for this issue: Weston C. Kirk

Willamette Management Advisors Autumn 2022 Insights

Estate and Gift Tax Planning Thought Leadership

Income Tax Thought Leadership

Bankruptcy Thought Leadership

Summer 2022: Thought Leadership in Professional Practices and Licenses Valuation, Damages, and Transfer Price Analyses

Editor for this issue: Samuel S. Nicholls

Willamette Management Advisors Summer 2022 Insights

Professional Practice Valuation, Damages, and Transfer Price Thought Leadership

Professional Practices and Licenses Valuation Thought Leadership

Income Tax Thought Leadership

Winter 2022: Thought Leadership in Unit Valuation Principle Property Tax Appraisals

Editors for This Issue: Connor J. Thurman and John C. Ramirez

Willamette Winter 2022 Insights Cover Page

Intellectual Property Valuation

Federal Income Tax Thought Leadership