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Valuing Minority Interests in the UK Is ‘Especially Challenging’

Comments by Andrew Strickland, a consultant with Scrutton Bland in the UK, on transactions involving fractional interests in closely held companies. He also offers a summary of discounts from a sample of relatively recent cases.

Valuing minority interests in the United Kingdom is ‘especially challenging’

‘Valuing fractional interests in closely held companies is especially challenging,’ Andrew Strickland reports to BVWire—UK.

Court Spotlights Lack of Control in Oil and Gas Interest Valuation

Appeals court affirms trial court’s discounting for lack of control and marketability in valuing oil and gas interests where trust’s ownership in interests was fractional and indirect and there was testimony regarding IRS’s estate tax discount rates.

Taubman v. U.S. Bank, N.A.

Appeals court affirms trial court’s discounting for lack of control and marketability in valuing oil and gas interests where trust’s ownership in interests was fractional and indirect and there was testimony regarding IRS’s estate tax discount rates.

Intrinsic Value Review Precludes Inclusion of Fractional Discounts

The appellate court finds that, performing the requisite intrinsic value review, the circuit court properly declined to include in its analysis any discounts the husband’s expert proposed to account for his fractional interest in companies owning hotels ...

Patel v. Patel

The appellate court finds that, performing the requisite intrinsic value review, the circuit court properly declined to include in its analysis any discounts the husband’s expert proposed to account for his fractional interest in companies owning hotels ...

11th Circuit Affirms Shepherd v. Commissioner

This gift tax case is an appeal from the Tax Court's December 2000 decision, which was abstracted in the December 2000 issue of Shannon Pratt's Business Valuation Update®, at page 5.

Shepherd v. Commissioner (II)

Issues were characterization of ifts as indirect gifts and proper application of stipulated combined minority and marketability discount.

34th Annual University of Miami Philip E. Heckerling Institute on Estate Planning - Chapter I: Fractionalized Equity Valuation Planning: Preservation of Post-Mortem Valuation Discounts

The University of Miami Philip E. Heckerling Institute on Estate Planning has published its 2000 Edition, 34 th Annual. This one-volume publication provides cutting edge articles based on lecture ...

Blockage Discount Appropriate for Apartment House

The taxpayer was granted a 20% fractional interest discount and an 11% blockage discount with apartment house properties, based on comparable sales and an analysis of market conditions and the economy.

Estate of Stevens v. Commissioner

In valuing 50% undivided interest in three commercial real properties, Tax Court rejects limiting discounts to costs of partitioning, finding 25% discount is appropriate for all properties and is in line with factor analysis for fractional interests.

Estate of Brocato v. Commissioner

At issue is whether respondent is equitably estopped from assessing additional estate tax, and if not, the proper amount of blockage and fractional interest discounts to be applied to petitioner’s nine real properties must be determined.

11% Blockage Discount Applied in Apartment Valuations

The taxpayer in this estate tax matter was granted a 20% fractional interest discount and an 11% blockage discount with apartment house properties, based on comparable sales and an analysis of market conditions and the economy.

Fractional Interest and Blockage Discount Considered

The Tax Court considered the size of discounts for blockage and fractional interests on nine rental properties.

Young v. Commissioner

Respondent determined an estate tax deficiency of $154,545.

Estate of Young v. Commissioner

Issues were whether properties were joint or community property, whether a marketability or fractional interest discount was applicable.

Estate of Cervin v. Commissioner

In valuing 50% undivided interest in farm and homestead, Tax Court determines 20% discount should apply to each of decedent’s fractional interests.

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