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Supreme Court Holds Value of Closely-Held Business Stock Includes Life Insurance Proceeds
Stinson
June 14, 2024 "[In] the 'redemption debt' scenario, Crown C's balance sheet remained unchanged. $3 million in cash disappeared, but the redemption (a purchase and retirement as 'treasury stock' of the redeemed shares) brought Michael's shares into Crown C -- obviously, at the redemption price. Thus, the economic effect of the redemption was not to decrease the value of Crown C but, rather, to increase, dramatically, the value of Thomas' shares, which, post-redemption, represented 100% ownership of Crown C.... [T]he real-world impact of Connelly will likely be a substantial reduction in the use of entity purchase shareholders' agreements funded with life insurance. " [Connelly v. IRS, No. 23-146 (S. Ct. Jun. 6, 2024)] |
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