For instance, the grantor may restrict the trustee's ability to invest in hard-to-value assets, such as closely-held stock.
closely-held stock where the CRT owns more than 49% of the combined voting power of all classes of stock; or
The foundation, for example, already offers donor-advised funds, and expects to launch new services that might include accepting or transferring closely-held stock
and gifts for real estate, she said.
* Appraisal may be needed for some closely-held stock
to determine appropriate value of tax deduction.
6 Question #6: A client donated closely-held stock
or real estate to his private foundation or charitable remainder trust.
Conversely, Lloyds associations, closely-held stock companies, and (to a lesser extent) widely-held stock companies have a comparative advantage in writing insurance for which managerial discretion is more important.
Table 1 reports separate logistic regression results (estimated via maximum likelihood) for group and nongroup companies.(8) We omit the Lloyds dummy variable from regressions 1, 2, and 3 and both the Lloyds and closely-held stock dummy variables from regressions 4, 5, and 6 to avoid singularity in the independent variable matrices.
Similar discounts are available for lack of marketability of the closely-held stock
. These discounts can run as high as 35% or more of the total value of the company.
In the past, the Tax Court has repeatedly held that no reduction in the value of closely-held stock
to reflect potential capital gains tax is warranted where a liquidation or a sale of the corporation's assets is purely speculative.
We argue that the analysis of managerial control problems of mutuals also applies to stock companies owned by mutuals, and that the incentives associated with Lloyd's are similar to those for closely-held stock companies.
In the next section, we classify ownership of stock insurers and discuss the differences between widely-held stocks, closely-held stocks, stocks owned by mutual insurers, and stocks owned by associations.
According to the ruling, "Potential future income is a major factor in many valuations of closely-held stocks
, and all information concerning past income which will be helpful in predicting the future should be secured ....