The starting point in thinking about all this is the asset.
The appraiser needs to meet certain education and experience requirements with respect to the particular type of asset. Lots of time, there’s no problem. For example, a licensed real estate appraiser ordinarily will meet the necessary education and experience requirements to appraise donated real estate by virtue of his or her license.
That’s because, in the language of IRS’s new regs on qualified appraisals, it’s customary for licensed real estate appraisers to appraise real estate.
But what if the property in question is, say, an operating vineyard? The issue here is whether it’s customary for appraisers holding the particular license to appraise vineyards. If it isn’t customary, the license holder must have at least two years of actual experience in appraising vineyards.
Who came up with the two-year rule? The IRS.
Now, there’s a related new requirement that pertains to the contents of the appraisal.
The appraiser needs to state, in the appraisal, not only his or her education and experience relative to appraising but also that because of this education and experience, he or she is qualified to appraise the donated asset.
There’s a lot, including a lot more, to IRS’s new regs on qualified appraisals.
For details, check with your SHARPE newkirk consultant.
by Jon Tidd, Esq