Estate and gift tax – Often the largest element in an estate is an interest in a family business. We have extensive experience in appraisals for estate and gift tax purposes, and we keep up to date with all of the Tax Court rulings which affect gifts and estates. We provide well-reasoned analysis of the discounts applicable to transfers of interests in family partnerships; we do not simply look for an acceptable “safe-harbor” conclusion, because we understand that a conclusion without support, however safe, is easily challenged. We have significant experience in family limited partnership and family LLC valuations, including tiered structures involving securities, real estate, and intangible assets.
S-corporation conversions – The conversion from C-corporation to S-corporation status can be of tremendous benefit to business owners, but there can be a price to pay if the business is sold within ten years of the conversion, whether for strategic reasons or due to death or disability; the gains in value that were “built-in” and a part of the business value at the date of conversion are subject to double taxation as if the S-corporation conversion never occurred. We recommend that any mid-size to large corporation converting to S-corporation have a full business valuation at the time of conversion to document the value of the business at the conversion date.
Charitable deductions – The value of a deduction for a gift of non-publicly-traded stock to a charitable organization must be documented with an appraisal if the value of the gift exceeds $5,000.
Compensation Analysis - CapVal, LLC has worked with many high-technology businesses from inception through successful initial public offerings. We understand the risks involved in a new enterprise, and we understand that qualified employees deserve the opportunity for significant future rewards for the risks taken in joining a new business. We have extensive experience in providing the required valuations of common stock options and stock grants often used as elements of compensation by companies in their inception and rapid-growth phase; and we have experience in helping our clients work through the requirements of Internal Revenue Code Section 409(A).
