valuation firms specializing in Section 1374 net unrealized built-in gain determinations at C-to-S conversion
Proper NUBIG valuation at conversion locks in tax exposure for five years.
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11 stories in Tax Valuation Concepts.
Proper NUBIG valuation at conversion locks in tax exposure for five years.
Two valuation methods produce vastly different tax and accounting outcomes for intangible assets.
How illiquidity discounts stack differently for privately held business interests.
Get the strike price above fair market value or your employees face the tax penalty.
How appraisers measure goodwill to satisfy the IRS on estate and gift tax returns.
GAAP and tax use different standards to allocate acquisition price with real cash consequences.
Misclassifying assets as real or personal property can cost decades of tax deductions.
Converted S corporations face a five-year tax on appreciated assets inherited from C-corp status.
The statute uses a precise list—not facts-and-circumstances—to define who qualifies as related.
Sellers lose negotiating leverage when they don't map liabilities before going to market.
Section 197 creates a fixed 15-year deduction for acquired intangibles.