Tax Planning and Reporting Opinions
Estate and Gift Tax Opinions
The high tax rates in the federal transfer tax system make wealth preservation of paramount importance for high-net-worth individuals, including owners of closely held businesses. Thus, to ensure accurate estate and gifting plans for asset management, Salter Group provides the following types of services to assist tax attorneys, certified public accountants, private bankers, financial planners and their clients, as well as the IRS:
- Valuations of interests in closely held business or other securities in support of gifting or estate tax returns.
- Discount studies for family limited partnerships, limited liability companies or other estate planning vehicles.
- Litigation support and expert witness testimony in IRS appeals, or other tax court or legal matters.
We also perform business valuations for equity, debt and securities in privately held companies. Our valuations are used in:
- Estate and gift tax planning
- Estate and gift tax return filings
- Buy-sell and cross-purchase agreements
- Key person insurance funding
- Recapitalization of common stock to preferred stock or non-voting common stock
- Charitable gift transactions such as charitable remainder trusts
Enterprise, minority interest and non-marketable minority interest business and asset valuations
In many cases, ownership in businesses and assets is held through illiquid securities or interests with “non-marketable” characteristics. Such ownership may be further complicated if it reflects a minority (non-controlling) interest. Since its inception, Salter Group has had extensive experience and expertise in valuing minority interests and illiquid securities across various asset classes in a variety of circumstances. Such work has been supported through consideration of asset- and business-specific factors as well as third-party research and information.
Equity/Share Based Incentives and Compensation For Services – IRS Sec. 409A
In October 2004, Congress established IRC Section 409A to effectively cause companies to establish defensible valuations of equity used to pay parties providing services to the company. Having extensive experience in valuing equity-based compensation such as nonqualified stock options, stock appreciation rights, stock units and phantom stock, which are all subject to 409A, Salter Group is able to provide cost-effective, Wall Street-credible, independent valuations that ensure clients to be in compliance with such requirements.
