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Taxation & Succession Planning

We have worked with thousands of companies, preparing thoroughly researched and well documented narrative appraisal reports that have been attached to thousands more income, estate and gift tax returns.

  • Our values and reports are also used to establish basis in the hands of heirs and in general succession planning.
  • Each year we prepare dozens of qualified appraisals used in support of charitable contributions of nonmarketable assets.
  • We have prepared numerous 409A and 83(b) valuations in the pharmaceutical, technology, private equity and fintech industries, often having to deal with complex capital structures.
  • Through counsel, clients seeking asset protection retain us to prepare values in connection with transfers to irrevocable trusts.
  • We have assisted attorneys and accountants by defending our appraisals in meetings with Internal Revenue Service agents and appeals officers.
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  • Our professionals have testified in the U. S. Tax Court, both as experts on behalf of the Government (see the Lauder buy-sell case) and the taxpayer (the Borgatello trapped-in gains case).
  • Our experience on both sides of the aisle provides us with insights not available at the typical valuation firm.
  • What’s more, our thorough and reliable appraisal reports can keep you from ever having to undergo the rigors of a very public tax-related trial.
  • We are particularly adept at valuing “frozen” securities in private entities, including standard and balloon preference interests and preferred stock.
  • We have prepared S election, built-in gain valuations for companies in all types of industries, from landfills and quarries, to motor vehicle parts remanufacturers, to wholesale beer distributorships and home healthcare franchises.

Other recent engagements have included the following:

  • Assisting counsel in achieving audit settlements with the Service involving gifts and sales of minority interests in several large (from $500 million to $2 billion in sales) client companies.

  • Preparing semi-annual valuations of the common stock of a privately owned mutual fund management company for grantor retained annuity trust creation and distribution purposes. We assisted counsel in defending the report and value over the course of several months, and later received word that our value had been accepted as filed with the Internal Revenue Service.

  • Determining the fair market values of ownership interests in over 50 closely held entities, including limited liability companies, partnerships and S corporations, for estate tax filing purposes. A high-pressure engagement with many complexities, we determined the fair market values of the ownership interests in question and issued an accompanying 700-plus page narrative report, ahead of schedule and within an extremely short time frame.

  • Preparing an 83(b) valuation for an Asian-based pre-revenue higher education social networking firm.

  • Preparing valuation analyses for an individual considering converting a regular IRA to a Roth IRA. The underlying investment in the account consisted of convertible preferred stock in a fintech start up.

  • Providing valuation services in connection with the sale of a derivative contract tied to the future performance of the principal’s carried interest in a private equity fund.

  • Valuing the restricted securities (subject to Rule 144) held by board members, CEOs and other insiders of public traded companies in the technology in healthcare sectors.

  • In recent years, we have provided appraisal services for a number of tech startups. Our most recent engagement involved determining the fair market value of the equity of a pre-revenue software company, which was involved in the development of a new social networking platform. In doing so, we initially applied traditional valuation approaches in order to derive a preliminary indication of value. We then tested the reasonableness of our preliminary findings by applying several methodologies designed specifically to provide indications of the pre-money valuation of a firm, including the Berkus, Risk Factor Summation, and Scorecard methods, in addition to considering the standard investment deal structure offered by Y Combinator, one of the top incubator and seed accelerator investment firms in the world.