This disposal process should in theory have no correlation with the Special Liquidator valuation and disposal process or indeed the Department of Finance.

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Nonetheless, the gift of a profits interest could violate special estate and gift tax valuation rules for freeze transactions (section 2701).

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In the case of Facebook, it agreed to what at the time seemed a high valuation, waived any right to special treatment should things go wrong and was willing to buy stock from employees.

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