What is the "en bloc value" of a minority shareholder's shares?
British Columbia, Canada
The following excerpt is from DeMarco v Imperial Ginseng Products Ltd., 2019 BCSC 1860 (CanLII):
As Pitfield J. pointed out in Grandison v. NovaGold Resources Inc., 2007 BCSC 1780, at para. 152, courts in this jurisdiction have declined to equate “fair value” with “fair market value”: [I]t is not the market value of the dissenter’s shares that is the center of attention. The focus is the determination of the en bloc value of all shares in the company, and the allocation of a proportionate share thereof to the dissenter. As a result, the minority discount that would ordinarily be applied when determining the fair market value of a minority interest is ignored. Notwithstanding these differences, it must be acknowledged that en bloc value is the fair market value of all issued shares of the company.
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