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The BIG Unknown

One of the questions that practitioners ponder is how to properly discount the value of stock in a closely held C corporation to reflect the future income tax liability on the corporation's unrealized built-in gains (BIGs). For transfer-tax purposes, this is known as the built-in gain discount (the BIG discount). The proper computation of the BIG discount has perplexed courts and practitioners alike.
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One of the questions that practitioners ponder is how to properly discount the value of stock in a closely held C corporation to reflect the future income tax liability on the corporation's unrealized built-in gains (BIGs). For transfer-tax purposes, this is known as the built-in gain discount (the “BIG discount”).

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