Monday, March 28, 2011
William H. Frazier (Senior Managing Director of Howard Frazier Barker Elliott, Inc.) recently published his article entitled Valuation Discounts in Tiered Investments, Trusts & Estates (Oct. 2010). The introduction is below:
Does the additional layer add new risks to the market value analysis? The subject of tiered discounts is a controversial one. Taxpayers may view the application of a tiered discount as a means to achieve a better tax result. Those who are already critical of valuation discounts see the additional layer of discounts as a blatant tax devise. In reality, there are times when such discounts are warranted and can be verified by similar constructs existing in the marketplace. There are other times when such discounts are, indeed, excessive and unjustifiable.