Tiered valuation discounts: How low can you go?

Description

Abstract: Valuation discounts can substantially lower the fair market value of gifted business interests. But business interest owners often inquire as to whether additional discounts apply when multiple layers of ownership exist. The answer is, maybe — if each entity exists for a bona fide business purpose. This brief article uses a landmark case, Astleford v. Commissioner, to examine the ramifications of tiered valuation discounts.