On a recent flight, I met a lady who works in the charitable giving area for a major institution. We talked for a bit and I asked if she was familiar with the idea of asking business owners to consider making gifts to her charity of appreciated shares in closely held businesses. She was familiar […]
In this post, Chris Mercer takes a deeper dive into the factors influencing marketability as listed in the IRS DLOM Job Aid.
There was pent-up demand for selling businesses in 2008. Now that we are on the short side of 2012, that pent-up demand is causing unknown pressures for business owners, their families, and their employees, who are uncertain about the necessary transitions that await. The tsunami is coming. Will you be ready? Will your clients be ready?
In this second post, Chris Mercer dives deeper into the Citigroup / Morgan Stanley buy-sell agreement outcome. If these results can happen to Citigroup and Morgan Stanley, they can certainly happen to you.
Overview of a Two Part Series Morgan Stanley and Citigroup entered into a joint venture (JV) dated as of May 31, 2009, with Morgan Stanley owning 51% and Citigroup owning the remaining 49% of the common member interests in Morgan Stanley Smith Barney Holdings LLC (“MSSBH”). The JV was evidenced by the Amended and Restated […]
Chiu v. Chiu is a New York statutory fair value case that is at the tail end of a lengthy dispute between two brothers. The case involved a dispute over the relative ownership positions of the two brothers in the LLC as well as over the fair value of the interest. I was the business valuation expert for the “out” brother. A New York appraiser worked on behalf of the “in” brother.
In this installment of the series “Understanding the Largest Valuation Discount,” Chris Mercer discusses the Benchmark Methods found in the IRS DLOM Job Aid.
This post discusses the “General Marketability Discount Information” section of the IRS DLOM Job Aid.
The DLOM is an issue in virtually every gift or estate tax matter involving minority ownership interests in businesses, partnerships, limited liability companies and more. In this post, we review the “Executive Summary” and “Introduction” sections of the IRS DLOM Job Aid.
This post introduces the discussion of the IRS DLOM Job Aid. The IRS DLOM Job Aid is a manual for IRS employees to assist them when evaluating marketability discounts. It is not an official IRS position; however, it is an important document because we believe that it will likely be a much-referenced document as well as fodder for cross-examination.