Business Valuation and Taxes: Procedure, Law and Perspective ...
Potential Earnings and Synergies Relevant in Determining Fair Market Value of Transferred Subsidiary
The issue in this corporate income tax matter is the fair market value, for purposes of IRC §§ 311(b) and 482, of Schlegel UK Holdings Ltd. and Schlegel GmbH, which were transferred from the taxpayer, BTR Dunlop Holding, Inc., to the taxpayer's parent corporation, BTR, Plc.
At issue is breach of fiduciary duty in connection with the cash-out of the minority shareholders in three related corporations.
At issue is the value of the common stock of Bowser, Inc., owned by the decedent.