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Perspectives – July 2025

Editor for this issue: Jackson L. Crispin, vice president, of our Atlanta office.

U.S. flag flying in front of a courthouse, suggesting a landmark legal decision

Tax Court Allows Tax-Affecting for the Discounted Cash Flow Method in Pierce v. Commissioner

Pierce v. Commissioner is the latest case to be decided that addresses the appropriateness of including income tax in the valuation of a privately held company organized as a pass-through entity. The decision also addressed financial forecasts, company-specific risk, and excess working capital, among other elements of business valuation.

Conflict Transactions and the Evolution of the Fairness Opinion Landscape

When navigating a conflict transaction, fiduciaries must demonstrate independence, informed judgment, and proper procedure. A fairness opinion, when properly executed, can deter or defend against litigation and serves as evidence of proper governance process.

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The Application of the Relief from Royalty Method for Intellectual Property Valuation

The relief from royalty method is a generally accepted valuation method for the analysis of intellectual property assets that may generate royalty income. Valuation analysts applying the relief from royalty method should be familiar with the procedural steps and key considerations of the method.

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