News & Insights: angela sadang

Valuation Discounts Applicable to Real Estate Holding Companies (PART 2)


By Angela Sadang  |  August 19, 2019

In part two of this two part series, Principal and valuation specialist Angela Sadang discusses the discount for lack of marketability, or DLOM, with regard to real estate holding companies.

Valuation Discounts Applicable to Real Estate Holding Companies


By Angela Sadang  |  May 29, 2019

Principal and valuation specialist Angela Sadang discusses real estate holding companies and the use of minority discounts (also known as the discount for lack of control, or DLOC) in the valuation of partial, non-controlling interests in entities holding real estate as their primary and most valuable asset. 

How much is artificial intelligence worth?


By Angela Sadang  |  February 5, 2018

Angela Sadang was recently published in the H1 2018 issue of Global Opportunities Bulletin. Her article addresses the growing artificial intelligence industry. 

On boarding a new transfer pricing client


By Angela Sadang  |  August 29, 2017

Angela Sadang was recently published in the H1 2017 issue of Global Opportunities Bulletin. Her article addresses the importance of understanding a new client’s business when initiating a transfer pricing engagement and developing the appropriate transfer pricing policy and methodology.

Transfer Pricing Business Models


By Angela Sadang  |  January 27, 2017

A key factor in establishing a reasonable transfer price is establishing the business model used by sales and distribution organizations. In this article, the authors describe the three primary models and their relevance establishing and defending a transfer price.

PREPARING FOR THE SALE OF YOUR BUSINESS


By Angela Sadang  |  January 27, 2017

So, you founded your business and, over the years, built it into the profitable — and flourishing — operation it is today.  Or maybe you inherited the business, maybe even bought out an existing enterprise.  But, whatever your path to success, you’ve no doubt worked hard and long to get to where you are.

Creating the Bridge Between Transfer Pricing and the Valuation of Intangibles


By Angela Sadang  |  May 11, 2016

International mergers and acquisitions (M&A) are at their hottest pace since before the 2008 financial crisis, and an increasing percentage of this activity involves intangible assets as significant components of the transaction. 

As multinational companies shift ownership of intangible assets between legal entities and across jurisdictions for various strategic purposes, the most critical considerations in cross-border M&A include the identification and valuation of intangible assets and transfer pricing. 

In the article, Director Angela Sadang challenges the perception that the value of a transaction and its largely-acquired intangible assets is motivated by financial reporting valuation rather than by transfer pricing valuation. Moreover, she discusses the importance of aligning the two disciplines early on in the M&A process to create lasting, value-added synergies. 

This article, "Creating the Bridge Between Transfer Pricing and the Valuation of Intangibles," appeared in the May version of the Quick Read Buzz.  

Taxing Intangible Assets: A New Global Approach


By Angela Sadang  |  April 28, 2016

In this article, Angela Sadang Director with the firm's Financial Advisory Services group, looks at the OECD’s 2015 final report on all 15 Action Plans, the aim of which was to, “restore confidence in the international tax framework by addressing weaknesses that create opportunities for BEPS”.  After pinpointing the important functions that contribute to the value of the intangible,  the piece goes on to discuss the ways in which to identify the intangibles that make up a particular transaction, as well as a look at five transfer pricing methods the OECD thinks would be appropriate when transferring intangibles, or rights in intangibles.

This article was originally published in Morison KSi's quarterly tax newsletter, Global Tax Insights, Q1 2016. It was reprinted by permission in Global Tax Weekly, April 28, 2016, published by CCH, a Wolters Kluwer business.

What's Next? Implications of Proposed IRS Regulations on Family-Owned Entities


By Angela Sadang  |  February 1, 2016

At the American Bar Association’s Section of Taxation meeting in May 2015, Cathy Hughes, Estate and Gift Tax Attorney Advisor with the US Treasury Department’s Office of Tax Policy, indicated that proposed regulations under IRC Section 2704(b)(4) (§2704) concerning restrictions on valuation discounts pertaining to the transfer of family-owned entity interests could be issued by mid-September 2015. As of this writing, no such regulations have been issued, though further informal communication on behalf of the Internal Revenue Service (IRS) suggests that new regulations are forthcoming. Meanwhile, questions and speculations abound. In a recent article, Angela Sadang discusses the implications of these proposed regulations on family-owned entities.

This article, “What's Next? Implications of Proposed IRS Regulations on Family-Owned Entities”, was originally published in the February 2016 issue of Metropolitan Corporate Counsel.

Finding an Intersection Between Intangibles Valuation and Transfer Pricing


By Angela Sadang  |  July 9, 2015

In the recent boom of cross-border merger and acquisition (M&A) activity, the large proportion of transactions involving intangible assets or intellectual property (IP) as a dominant acquired asset has shed light on the importance of the identification and valuation of intangible assets and transfer pricing.

In this article, director Angela Sadang discusses how aligning these two disciplines early on in the M&A process can create lasting, value-added synergies.

This article, “Finding An Intersection Between Intangibles Valuation and Transfer Pricing in the US”, was originally published in Morison International’s quarterly tax newsletter, Global Tax Insights, Q2 2015.  It was reprinted by permission in Global Tax Weekly, July 9, 2015, published by CCH, a Wolters Kluwer business

New Methods Promise More Accurate Valuations of Small, Privately Held Businesses


By Angela Sadang  |  July 2, 2015

Accurate valuation of any business is challenging. When the business is small and privately held, the challenge is all the greater. In the past, appraisers have used public company stock return data as a benchmark for valuing small private businesses. There are significant problems with this approach as appraisers have been challenged to find alternate data that might yield more accurate valuations. Fortunately, this is changing as new developments offer appraisers alternate data that might result in more accurate valuations.