How to Discount for Trapped-In Capital Gains Tax
BVR's Webinar Series
Tuesday, August 17, 2004
12:00am-2:00am PT • 3:00am-5:00am ET
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- Estimating the taxes on unrealized appreciation of equity portfolios of "C" corporations
- Importance of the dividends and the dividend exclusion
- Importance of operating and liquidation expenses
- Importance of the holding period
- Importance of the tax basis
- Why the problem of deferred taxes on unrealized appreciation may be applicable to all non-operating assets
- The theory of built-in gains taxes in C corporations
- Frazier's Formula:
- Net Asset Value means Fair Market Value of the Entity's Assets Less All of the Liabilities;
- FMV must be calculated as of a certain date;
- Value implies money; Money implies a transaction;
- A transaction is a transfer;
- The transfer triggers capital gains tax
- The Dunn case
- The pending Jelke case
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