ALASKA FOCUSED VALUATION
Estate & Gift Valuation
Independent valuation services for estate and gift tax reporting, performed on a fair market value (FMV) basis in accordance with IRS requirements.
These engagements require disciplined evaluation of both entity-level economics and ownership-level rights.
Scope of Work
Estate and gift valuation may include:
- Business ownership interests
- Holding company and multi-entity structures
- Asset-intensive operating businesses
- Real estate-integrated enterprises
Assignments are performed selectively, typically involving:
- Estate tax reporting
- Gift tax reporting
- Ownership transfer and planning
Valuation Context
Valuation is required where:
- Ownership interests are transferred between related parties
- Estate settlement requires value determination
- Gift reporting requires compliance with IRS standards
All conclusions are developed under the fair market value standard, reflecting:
The price at which property would change hands between a willing buyer and a willing seller, both having reasonable knowledge of relevant facts and neither being under compulsion to act.
Ownership-Level Analysis
These engagements require disciplined evaluation of both:
- Entity-level economics (cash flow, assets, capital structure)
- Ownership-level rights (control, governance, transferability)
Types of Discounts Commonly Addressed
Lack of Control (Minority Interest)
Reflects the economic limitations associated with non-controlling ownership, including:
- No unilateral control over operations or asset disposition
- Limited influence over distributions and financing
- Subordination to controlling owners and governance provisions
Control analysis is based on actual rights, not nominal ownership percentages.
Lack of Marketability
Addresses the reduced liquidity and transfer restrictions inherent in closely held interests, including:
- Absence of an active secondary market
- Transfer restrictions and consent requirements
- Long expected holding periods
- Capital lock-up and distribution uncertainty
Marketability analysis is tailored to the specific entity structure and governing documents.
Discount Discipline
Discount analysis is conducted using a conservative, examination-oriented framework.
Based on IRS audit and examination experience, emphasis is placed on:
- Alignment with applicable case law and published precedent
- Empirical support (restricted stock and partnership transaction studies)
- Structure-specific analysis rather than mechanical discount ranges
- Explicit documentation of economic and governance constraints
This practice does not pursue aggressive discount strategies designed solely to maximize short-term tax reduction.
The objective is sustainable valuation, not headline discounts.
Partial Interests & Tiered Ownership
Complex estate structures frequently involve layered ownership, including:
- Multi-tier holding company structures
- Cross-owned partnerships and LLCs
- Sequential partial gifting programs
- Family recapitalizations (voting / non-voting structures)
Each ownership layer is analyzed independently to assess:
- Incremental loss of control
- Compounded marketability constraints
- Inter-company governance effects
- Cash flow and distribution subordination
Integration with Transfer Planning
Minority interest and discount analyses are commonly applied in connection with:
- Grantor Retained Annuity Trusts (GRAT)
- Spousal Lifetime Access Trusts (SLAT)
- Family Limited Partnerships (FLP)
- Installment sales and staged gifting programs
- Tiered trust and partnership structures
Valuation conclusions are coordinated with legal and tax advisors to ensure consistency with the governing planning strategy.
Positioning
Estate and gift valuation is provided as part of a broader valuation practice and is not the primary focus of the firm.
Assignments are accepted selectively, particularly where:
- Ownership structure is complex
- Enterprise and asset components are interdependent
- Valuation must withstand professional and regulatory scrutiny