Tag Archives: due diligence

CAN PARTNERS’ ARM’S LENGTH AGREEMENTS ON VALUATION SURVIVE IRS SCRUTINY?

In a recent Tax Court case, the IRS attempted — unsuccessfully — to supplant the fair market value agreed to by unrelated parties in a partnership transaction with its expert’s higher estimate, asserting that the taxpayer received a taxable capital interest in exchange for services provided to a partnership, not a nontaxable profits interest. If Read More…

M&A STORIES – HOW TO ‘DEAL’ WITH UNWELCOME SURPRISES

Surprises are rarely good. There are many different emotions that come with the experience of surprise: fear, anxiety, and joy—to name a few.  Deals can also cause the same emotions for a deal maker. Perhaps the booked pipeline was stronger than expected or new management, while unproven in historical results, has the ability to create Read More…