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Thompson Coburn publishes article on personal goodwill in asset sales
Thompson Coburn said it published an article by Mariquita Barbieri and Nicholas Engel on personal goodwill as a tax-saving opportunity in C corporation asset sales. The firm said a shareholder’s sale of personal goodwill, distinct from corporate goodwill, can be taxed once rather than at both corporate and shareholder level, citing Martin Ice Cream Co. v. Commissioner, and said allocations need a qualified valuation, separate agreements and consistent reporting by both parties.
Key points
- Thompson Coburn’s article discussed shareholder relationships with customers.Thompson Coburn
- The publication examined valuation of personal goodwill.Thompson Coburn
- The firm’s article covered agreements supporting the allocation of purchase consideration.Thompson Coburn
- The publication also addressed consistency in transaction reporting.Thompson Coburn