409A Enforcement Actions

Not too much is my impression as FMV is so tricky in the private company context. For that reason though, it's good to have one to put the burden of proof on the IRS to show that it was unreasonable. Further, in the context of an acquisition, the target will have one less point to negotiate on if a safe-harbor valuation can be shown to the acquirer. This benefit will flow to the reps on tax matters as well as benefits matters. Good marketing points for you, when you pitch your valuation services. For my part, I've already done a couple voluntary option exercise price corrections under the 409A self-correction guidelines.