IRS modifies position and allows discounts on intra-family stock transfers

Article Abstract:

Revenue ruling 93-12 shows the IRS' acceptance of minority discounts for minority stock transfers between controlling family members, a reversal of its previous opinion because of several court decisions. Therefore, the IRS no longer requires an aggregate basis for valuing the interests. However, real estate fractional interests are not included in the minority discounts and the IRS can still contest other aspects of the transfers such as those effecting the corporate balance of power.

Securities, Family-owned business enterprises, Family-owned businesses, Stock transfer

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Characterizing the "new" transfers of intellectual property

Article Abstract:

The author discusses tax issues involved in the transfer of intellectual property, the law used to determine if a transfer is an exchange or license, and remaining issues for corporations and partnerships.

Intellectual property, Transfer (Law)

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Tracking stock: virtual equity, virtual entities, and virtual mergers and acquisitions

Article Abstract:

The authors present an analysis of tracking stock and issues regarding its taxation.

Analysis, Tracking stocks

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