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Appraisal Issues Surrounding the Leveraged Reverse FreezeAppraisal Issues Surrounding the Leveraged Reverse Freeze
A freeze transaction is an estate-planning technique that uses the interplay of the differing financial and valuation characteristics of preferred equity and common equity securities to transfer assets from one generation to another while minimizing estate and gift taxes. A reverse freeze is a wealth transfer strategy that uses a limited partnership (LP) or a limited liability company that's structured
Alex W. Howard & Bradley A. Gates
A freeze transaction is an estate-planning technique that uses the interplay of the differing financial and valuation characteristics of preferred equity and common equity securities to transfer assets from one generation to another while minimizing estate and gift taxes. A reverse freeze is a wealth transfer strategy that uses a limited partnership (LP) or a limited liability company that's structured to have both preferred and common interests (we'll assume the use of an LP structure). In a reverse freeze transaction, the transferred partnership interest is the preferred interest. The preferred partnership (PP) interest is structured to receive a preference return that's senior to any distributions made...
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