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Valuation of Real Estate Interests In Tiered EntitiesValuation of Real Estate Interests In Tiered Entities

Fundamental principles still apply regardless of structure.

16 Min Read
Valuation of Real Estate Interests In Tiered Entities

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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About the Authors

William Harris

William Harris is a  director at Trugman Valuation Associates Inc. in Parkland, Fla.

William H. Frazier

Managing Director, Valuation Services, Weaver

William H. Frazier, ASA, has over 40 years of experience in valuation, investment banking, mergers and acquisitions, and litigation advisory services. For the last 15 years, Will's career focus has included valuing family-owned businesses and holding entities, such as family limited partnerships. He has performed valuations for estate and gift taxation, fairness/solvency opinions, bankruptcy and reorganization, disputes related to business transactions and shareholder disputes, family law matters, purchase and sale advisement, employee stock ownership plans, equity compensation, financial reporting, and other litigation, tax and corporate matters. Additionally, Will has served as an expert witness and appraiser in several U.S. Tax Court cases.

Will is a senior member of the American Society of Appraisers (ASA) and former chair of the Government Relations Committee, former treasurer and secretary of the Business Valuations Committee (BVC) and head of ASA’s Task Reform Task Force. From 2008-2011, Will served on the Internal Revenue Service Advisory Council (IRSAC) where he was assigned to the Office of Professional Responsibility. He is currently a member of the Standards Sub-committee of the BVC and is the BVC’s liaison to the Government Relations Committee. He has authored numerous articles on the subject of business valuation for professional and business publications. Will is a frequent speaker and program presenter on the subject of estate and gift tax valuation.