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Valuation Discounts in Tiered InvestmentsValuation Discounts in Tiered Investments
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 device. In reality, there are times when such discounts are warranted and can be verified by similar constructs existing in the marketplace.
William H. Frazier
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 device. 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.
If merely adding a tier or layer to a business organization was the only justification for discounts, then sharp estate planners could quickly dissipate any potential transfer tax liability by simply adding a layer or two to their planning. ...
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