EBITDA is earnings before interest, tax, depreciation, and amortization. It is an important factor in valuing a business because it shows sort of the upper limit of what earnings can be with the current market.
The main way of valuing businesses is by the discounted cash flow of future earnings method. This looks at the EBITDA and projects its increase several years into the future. This is then discounted to account for the uncertainty of that scenario.
Corporations are a controlled group if all corporations are owned at least 80% by a parent corporation (26 U.S.C. § 1563(a)(1)) or if pairs of two corporations are owned more than 50% by the same 5 or fewer people, but only including stock the extent identical between the corporations. (If Jim owns 10% of X and 40% of Y, only count 10%.)
X & Y: 10% + 5% + 10% = 25%
X & Z: 10% + 25% + 10% = 45%
Y & Z: 30% + 5% + 45% = 80%
Example of Contributing Property with More Nonrecourse Debt than Basis
If the value is $500, basis $250, and debt $400:
First, $150 (400-250) of debt is allocated to the contributor.
Then, the remaining debt is distributed the same as gain. (If equally, $62.5 (cuz (400-250)/4))