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Blog Posts in 2015

Strategic Value

Is there really a strategic value that private firms can expect when they decide to sell? If so, how can they estimate the amount? Strategic value is a real, yet amorphous, concept. It is best defined ...
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TRANSFER PRICING IRC SECTION 482

Companies which transfer goods and services among offshore and related entities are subject to the provisions of Internal Revenue Code Section 482. Crucial to meeting these standards of objectivity is ...
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PERSONAL GOODWILL

If personal goodwill is not a property right of the enterprise, its value is not includable in the assets of the business. Thus, it is separable from business goodwill. What is personal goodwill? It ...
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Derivative Valuation

In financial terms, the derivative contract derives its value from the performance of an underlying property. This property – asset, index, or interest rate – is called the ...
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SECTION 1031: LIKE-KIND EXCHANGES INTANGIBLES MAY QUALIFY

In a Section 1031 exchange of properties, no gain or loss is recognized so long the properties are used for productive use in a trade or business or for investment purposes. In 2009 the Internal ...
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Fraudulent Conveyance

Fraudulent conveyance means an attempt to avoid debt obligations by transferring money or assets (value) to another person or company. The issue arises in debtor/creditor or shareholder relations. For ...
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Section 83(b) Election

Internal Revenue Code Section 83(b) provides for the taxpayer to elect to be taxed at the ordinary income tax rate upon receipt of an equity grant. This taxpayer election occurs as of the date of the ...
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IP Impact Growing

The use of IP value for loan collateral is more prevalent now than in the last eight years. Does that mean that senior lenders are actively pursuing these loans? Not exactly, as most IP-Collateralized ...
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Personal Goodwill

If personal goodwill is not a property right of the enterprise, its value is not includable in the assets of the business. Thus, it is separable from business goodwill. What is personal goodwill? It ...
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