![Valuation of Real Estate Interests In Tiered Entities Valuation of Real Estate Interests In Tiered Entities](https://eu-images.contentstack.com/v3/assets/bltabaa95ef14172c61/blt0be4797f63a1c11d/6734c8a46f26a93855298e93/moneystacks1thumbnail.jpg?width=1280&auto=webp&quality=95&format=jpg&disable=upscale)
The application of tiered discounts in the valuation of minority interests in closely held asset holding companies is often disputed by the Internal Revenue Service. When performing valuations for estate and gift tax purposes, business appraisers often encounter partnership structures that involve ownership of a noncontrolling ownership interest in other entities.1 For example, consider the valuation of a 25% percent minority interest in a partnership with a structure as shown in “Partnership With Tiered Structure,” p. 54.
In this case, the valuation subject (Partner B’s interest) owns a minority interest in a holding entity (partnership), which in turn owns minority interests in several other entities. It’s a normal and customary procedu...
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