PwC’s engagement to calculate the fresh capital needed to keep the remainder of ailing Travelex afloat has been completed with an agreement to provide £84 million.
Rev. Rul. 83-120 Section 2512. -- Valuation of Gifts 26 CFR 25.2512-2: Stocks and bonds. (Also Sections 305, 351, 354, 368, 2031; 1.305-5, 1.351-1, 1.354-1, 1.368-1, 20.2031-2. ) 1983-2 ...
On appeal, plaintiffs brought a punitive class-action suit alleging that the repurchase of shares in connection with an acquisition resulted in the impairment of capital.
Issue is whether directors breached their fiduciary duty of candor by failing to disclose material facts prior to shareholder approval of transactions.
Plaintiffs sought rescission on a series of transactions including a merger, stock repurchase and certificate amendment.
Plaintiffs sought recission on a series of transactions including a merger, stock repurchase and certificate amendment on theory that directors breached fiduciary duty.
One of the issues was the fair market value of the family trusts' MBI stock at the time of the recapitalization.
At issue is the valuation of the stock of a family-owned corporation for estate gift tax purposes.
The marketability discount issue in this case arose in connection with the question of whether the common stock decedent and his wife surrendered in a recapitalization of their family-owned corporation was worth more than the preferred stock they received, thus resulting in taxable gifts.