IRS sheds light on subsequent events and recycled valuation reports

Description

Abstract: A recent IRS Chief Counsel Advice memorandum offers valuable insight into the IRS’s perspective on whether subsequent events may be considered when estimating the fair market value of a private business interest for gift tax purposes. The memorandum — which can’t be used or cited as legal precedent — also addresses the issue of re-using previously issued valuations for gift and estate tax purposes. This article summarizes the key takeaways from this unofficial guidance. A sidebar explains when valuators may factor subsequent events into their analyses.