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The third method by which a controlling shareholder can extract private benefits of control is through freezing out minority shareholders at a market price that reflects a discount equivalent to the private benefits of control available from operating the controlled corporation.
In contrast, the rules that limit extracting the capitalized value of the private benefits of control through freezing out the non-controlling shareholders are both complex and restrictive.
The gains that result from freezing out minority shareholders require the contribution of both the controlling and noncontrolling shareholders; the gains must then be fairly divided between them.