CCA 201939002: Pending Merger to be Considered When Valuing Stock for Gift Tax Purposes (Sep. 30, 2019)

The Office of Chief Counsel issued an advice on whether a hypothetical willing buyer and seller of a publicly-traded company would consider a pending merger when valuing stock for gift tax purposes. The issue and conclusion of the CCA are as follow

ISSUE

Whether, under the circumstances described below, the hypothetical willing buyer and seller of shares in a publicly-traded company would consider a pending merger when valuing stock for gift tax purposes.

CONCLUSION

Yes. Under the fair market value standard, the hypothetical willing buyer and seller of a publicly-traded company would consider a pending merger when valuing stock for gift tax purposes.

See full CCA by clicking CCA 201939002: Pending Merger to be Considered When Valuing Stock for Gift Tax Purposes (Sep. 30, 2019).

Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal.