Page
27 of
141 members in the subject entity.
In summary, this revenue ruling states that a minority discount will not be disallowed solely because a transferred interest, when aggregated with interest
held by family members, would be part of a controlling interest. There are no accepted methods for direct determination of DLOCs. Generally, the
Mergerstat Review studies calculating control premiums (cited previously in Section 2.6.1 Control Premiums) are used to calculate implied discounts for lack of control
if the subject interest, in fact, requires a DLOC to arrive at a value on an equivalent basis to the interest being appraised. A DLOC will be considered and discussed in Section 5.5.2 Discount for Lack of Control – Subject Interest. Appropriate empirical studies and analyses will be Included in this discussion as required.
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