Chancellor Alistair Darling's preferred option is to see a sale of the whole company as a going concern to a willing buyer
. But yesterday's announcement that approaches have so far come in "materially below" the value of the company have left the scenario of an outright sale looking far less likely.
FMV is the price at which the used vehicle would change hands between a willing buyer
and a willing seller, neither being under any compulsion to buy or sell and each having reasonable knowledge of relevant facts.
Attempting to determine the price a willing buyer
and willing seller would agree upon is not an appropriate valuation method.
They all want the "willing seller, willing buyer
concept" that has kept most of the best ancestral lands in the hands of whites, to be removed.
France, Russia, and other nations with space programs already sell satellite photos to any willing buyer
Under this test, the FMV of an asset is the price at which it would "change hands between a willing buyer
and a willing seller, neither being under any compulsion to buy or to sell and both having knowledge of relevant facts." The courts have determined that the test is objective and relies on hypothetical parties rather than specific individuals; see, e.g., Est.
Generally, the value is what a willing buyer
would pay a willing seller to receive the economic benefits attached to a stock.
A hypothetical willing buyer
would account for this lack of control by demanding a reduced price (i.e., a price below the net asset value (NAV) of the pro-rata share).
Generally, the value would be what a willing buyer
would pay to receive the economic benefits attached to that amount of stock.
Beneficiaries can request the IRA custodian to distribute the IRA assets and then can sell them to any willing buyer
. The IRS also said that short administrative delays in processing the beneficiaries' request for distributions do not warrant a discount.
Since fair market value is defined as "the price at which such property would change hands between a willing buyer
and a willing seller, neither being under any compulsion to buy or sell and both having reasonable knowledge of relevant facts," the Tax Court concluded that a willing buyer
would take the form of the transaction--the creation of the partnership--into account and that the substance and form were not at odds for gift tax valuation purposes.