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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, Managing Director, Valuation Services

October 1, 2010

22 Min Read
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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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About the Author

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.