Determining Risks Resulted from Issued by Bucharest Stock Exchange

摘要

In its review of the Tax Court decision in Jameson, the Fifth Circuit noted that the stock value for estate tax purposes depends on the timberland's fair market value on the taxpayer's date of death. Any sale of the subject company shares would cause a transfer of the timberland which would trigger the built-in capital gains tax liability. The estate's valuation experts noted that the only sound economic strategy for a hypothetical willing buyer of the holding company would be an immediate liquidation of the timberland. This discussion will summarize the various issues related to the valuation of a C corporation with appreciated underlying assets. This discussion will also present a practical framework for quantifying the appropriate valuation adjustment (if any) related to the capital gains tax contingent liability related to such corporations.