News & Analysis as of

Appraisal Fair Market Value

J.S. Held

The Essential Role of Qualified Personal Property Appraisers in Estate and Donation Valuations

J.S. Held on

When purchasing an expensive engagement ring, one would not seek the expertise of a real estate agent. Similarly, when an estate requires an appraisal, it is crucial to engage the appropriate expert for high value personal...more

Offit Kurman

Not Realizing the True Value of “Stuff”

Offit Kurman on

For federal estate and gift tax purposes, transfers are valued at the “fair market value” of the asset on the date of transfer. One of the more common estate tax audit issues is the failure to properly report the value of...more

Offit Kurman

Not Hiring a Qualified Appraiser and Realizing the True Value of Art and Collectibles

Offit Kurman on

For federal estate and gift tax purposes, transfers are valued at the “fair market value” of the asset on the date of transfer. One of the more common estate tax audit issues is the failure to properly report the value of...more

Bricker Graydon LLP

Navigating ESOP Transactions: Essential Steps to Minimize DOL Scrutiny from the Start

Bricker Graydon LLP on

In a recent court ruling, the US Department of Labor (DOL) prevailed against corporate directors and shareholders for claims related to an Employee Stock Ownership Plan (ESOP) transaction. ...more

Polsinelli

Bare Knuckle Conservation Easement Brawl Leaves Participants in Limbo

Polsinelli on

Two recent tax court cases paint an ominous picture for professionals and investors who participated in listed syndicated conservation easement transactions. Coming on the heels of the Fisher conviction and his lengthy...more

Amundsen Davis LLC

Assessors Allowed to Use “Anticipated” Vacancy in Making Assessments

Amundsen Davis LLC on

Developer beware! In Wisconsin, assessors may use an “anticipated” vacancy in making assessments. Veritas Village LLC, the owner of a property with 189 apartments in Madison, contested the city's assessment of its property at...more

Bond Schoeneck & King PLLC

The Practical Effect of the Uniform Partition of Heirs Property Act

Under New York law, when real property has multiple owners who hold the property as tenants in common, any one co-owner can try to force the sale of the property by filing a partition under Article 9 of the Real Property...more

Lathrop GPM

Valuable Lessons in Charitable Deductions

Lathrop GPM on

A recent Tax Court case provides important guidance for donors and charities making and negotiating gifts of appreciated property. While generally donors who donate appreciated property to a public charity do not recognize...more

Hogan Lovells

Ramcell, Inc. v. Alltel: DE Court averages valuation models to arrive at fair market value of shares

Hogan Lovells on

In Ramcell, Inc. v. Alltel Corp., C.A. No. 2019-0601-PAF (Del. Ch. July 1, 2022), the Court of Chancery reviewed a 2019 short-form merger between Alltel Corporation (Alltel) and Jackson Cellular Telephone Co. (Jackson), that...more

Morris James LLP

Delaware Supreme Court Explains Appraisal Rights and Finds Disclosure Violation Relating to Pre-Closing Dividend Contingent on a...

Morris James LLP on

In re GGP, Inc. Stockholder Litig., C.A. No. 2018-0267 (Del. July 19, 2022) - Here, the defendants organized a merger so that a large majority of the total value of the merger would be granted as a pre-closing dividend to...more

Lasher Holzapfel Sperry & Ebberson PLLC

Valuing Real Estate in Divorce Cases

Washington State divorce laws provide that in every case the trial court must order a “just and equitable” distribution of the parties’ property and liabilities, whether community or separate. RCW 26.09.080. This includes...more

Skadden, Arps, Slate, Meagher & Flom LLP

In Appraisal Cases, Court of Chancery Increases Deal Price-based Valuation if Evidence Shows Pre-Closing Change

For the purposes of a statutory appraisal under Delaware law, a corporation’s fair value is determined “on the date of the merger” ― in other words, at closing, not signing. However, deal terms, including price, are typically...more

Farrell Fritz, P.C.

Recent Stock Valuation Decisions Reign “Supreme”

Farrell Fritz, P.C. on

The fair value and fair market value appraisal standards applicable in contested buyout and dissenting shareholder valuations cut across state lines, which is one of the main reasons I occasionally highlight significant court...more

Cooley LLP

Delaware (Again!) Requires Upward Adjustment to Deal Price in Appraisal Proceeding Despite Objectively Fair Sales Process

Cooley LLP on

A recent Court of Chancery decision adds yet another wrinkle to the appraisal landscape and the potential for appraisal arbitrage. In BCIM Strategic Value Master Fund LP v. HFF, Inc. (Del. Ch. Feb. 2, 2022), the court found...more

McDermott Will & Schulte

NFTs and Charitable Fundraising: Navigating Tax Hurdles

As the creation of and transactions involving non-fungible tokens (NFTs) have increased dramatically, so has interest in using NFTs as donations to charitable organizations and for other charitable fundraising tools. Given...more

Rivkin Radler LLP

Gifting Business Interests Before Selling the Business? Think Valuation

Rivkin Radler LLP on

Counting the Days?- We are 302 days away from the national mid-term elections, to be held November 8, 2022, yet the first full week of the new year has already highlighted some of the economic issues with which the...more

Morris James LLP

Delaware Supreme Court Upholds Contractual Waiver of Statutory Appraisal Rights

Morris James LLP on

Manti Holdings, LLC, et al. v. Authentix Acquisition Co., Inc., No. 354, 2020 (Del. Sept. 13, 2021) - This decision arose out of the acquisition of Authentix Acquisition Company, Inc. and a subsequent appraisal proceeding...more

Farrell Fritz, P.C.

Statutory Buyouts and Discounts Under the Fair Market Value Standard: An Awkward Pair?

Farrell Fritz, P.C. on

Valuation discounts can and often do play an outsized role in contested appraisal proceedings involving the valuation of equity interests in closely held business entities for which there is no public market....more

Morris James LLP

Superior Court CCLD Dismisses Complaint Seeking Insurance Coverage for Appraisal Proceeding

Morris James LLP on

Jarden, LLC v. ACE Am. Ins. Co., C.A. No. N20C-03-112 AML CCLD (Del. Super. July 30, 2021) - Director and corporate liability insurance coverage is determined by the specific language of the insurance policies. Last year,...more

Farrell Fritz, P.C.

Fueling the DLOM Debate: Control Transfer Restrictions and the Discount for Lack of Marketability

Farrell Fritz, P.C. on

Of all the factors considered by business divorce lawyers and appraisers when valuing an owner’s interest in a closely-held company, the calculation and applicability of a discount for lack of marketability (“DLOM”) is among...more

Cooley LLP

Blog - Keeping Up with Delaware Appraisal Jurisprudence Since Aruba: Deal Price Reigns Supreme, But Will Recent Decision Lead to...

Cooley LLP on

In a string of seminal decisions from 2017 through 2019 (DFC Global, Dell and Aruba), the Delaware Supreme Court re-shaped appraisal jurisprudence, in each case by overturning the Court of Chancery for failing to give...more

McDermott Will & Schulte

Special Report - A Primer on Charitable Contributions of Virtual Currency

The explosive growth in virtual currency (also referred to as cryptocurrency, digital assets, tokens and digital currency) is evidence of increasing popularity and acceptance of it as a new investment asset class. With the...more

Nossaman LLP

Another Appraisal Opinion Bites the Dust

Nossaman LLP on

In California eminent domain cases, appraisers typically have relatively wide latitude in determining fair market value for the property to be acquired. However, there are certain rules they must follow, and when an appraiser...more

Farrell Fritz, P.C.

Who Decides Disputed Valuation Under LLC Agreement’s Buy-Out Provision: Arbitrator or Appraiser?

Farrell Fritz, P.C. on

It’s not unusual to find buy-out provisions in shareholder and operating agreements that commit the pricing of the buy-out to the “final and binding” determination of one or more appraisers. The same agreements also may...more

Morris James LLP

High Court Affirms Deal Price Was Reliable Indicator of Fair Value Despite Flawed Process

Morris James LLP on

Brigade Leveraged Capital Structures Fund Ltd. v. Stillwater Mining Co., C.A. No. 427, 2019 (Del. Oct. 12, 2020) - This case illustrates that, notwithstanding a flawed process for the sale of a company, the deal price may...more

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