-48- The cruzado proceeds would remain subject to the same prohibition on repatriation, until April 14, 1999. F. Petitioner's Tax and Accounting Treatment of the Conversion NBM's chief financial officer and comptroller, Phil Williams, reviewed and analyzed the Corporate Finance study. Two days after the conversion he concluded that the estimated fair market value of petitioner's 14.361-percent equity interest in PCC was between $12.4 million and $12.6 million. Mr. Williams arrived at this conclusion by using the price/equity ratio and discounted cash-flow approaches, as well as adding a third approach, based on the net book value of PCC. He then weighted the three approaches equally.31 Mr. Williams recommended that the investment be recorded at par. In April 1987, Mr. Narayana (who was in charge of petitioner's Brazilian blocked deposits) agreed with Mr. Williams' conclusion. 31 Mr. Williams determined the fair market value of petitioner's interest in PCC as follows (numbers are in thousands): Method Total Company Norwest's Share Price/earnings ratio $ 79,385 x 14.361% = $11,400 Discounted cash-flow 79,790 x 14.361% = 11,459 Net book value 1100,386 x 14.361% = 14,416 Weighted average $ 86,520 $12,425 1 Discounted 20 percent.Page: Previous 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 Next
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