The Value of Invincibility in the UFC

How much is it worth to get kicked in the face?  If you’re Ronda Rousey, our answer may cheer you up a bit.

How much is it worth to get kicked in the face?

If you’re Ronda Rousey, our answer may cheer you up a bit.

The UFC wunderkind, who went undefeated during the last three years, suffered an unanticipated loss this past weekend during UFC 193, when a blow from kickboxer Holly Holm sent her crashing to the mats. She lost more than just her match and her title—she also lost her veneer of invulnerability, a central component of the Rousey mystique. So we were curious—did Holm’s kick do as much damage to Rousey’s brand value as it did to her upper lip?

Projected Fight Earnings

We looked at Rousey’s current projected fight earnings for 2016 through 2019 and compared it to an alternate scenario, which assumes she had won her match against Holm. We account for the fact that her medical suspension means she’ll only be able to manage 2 matches in 2016 instead of her usual 3 per year, but we also estimate that her viewership will grow at a slightly higher rate now that she’s more of a wildcard, rather than if she had continued her streak.

Our estimate for the end of 2016 shows that Rousey’s earnings would be roughly the same had she won or lost; but with 33% less time in the cage.  Said differently, her earning power for next year went up on a relative basis due to her loss last weekend.  We also estimate that viewership of her matches will go up over the next few years.  By the end of 2019, though, her cut on the bump in viewership will more than make up for the temporary setback of her loss—the increase in her present value between the two scenarios is about $4 million over the next 4 years.

Ronda Rousey Profit

It makes sense to assume that the loss of an athlete’s title would be followed by a loss in an athlete’s value. But that doesn’t take into account that invincibility is boring. People aren’t going to keep tuning in if they know what to expect. The UFC was running out of fighters to throw at Rousey until UFC 193, when they found a genuine rival for her in Holly Holm. Not only does this make the possibility of a rematch much more lucrative, it also means that Rousey is no longer predictable. The stakes are higher for every single match from here on out, because now we know she could lose—and that makes it even more thrilling to watch.

The Value Of Invincibility In The Ufc

Michael Conroy, CFA

DIRECTOR
mconroy@valuescopeinc.com

Mr. Conroy has more than 20 years of consulting and business valuation experience, concentrating on complex estate and gift valuation matters. He provides business valuation and financial consulting services to companies in a broad range of industries. Working with domestic and international clients, Mr. Conroy has performed thousands of business appraisals involving gift and estate tax, financial reporting, mergers, and acquisitions (valuations for buyers/sellers, fairness, and solvency opinions), litigation support, expert testimony, and other company requirements (including stock options and ESOPs). Mr. Conroy previously worked with the national valuation firm CBIZ Valuation Group, LLC here he was a senior manager. Prior to that, he taught chemistry and physics to high school and college students at Xavier College in Ba, Fiji, for two years as a U.S. Peace Corps volunteer.

 

Uncertainty Remains Around IRS Potential Treatment of Valuation Discounts

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IRS Valuation Discounts

At the American Bar Association meeting in May 2015, Cathy Hughes, Estate and Gift Tax Attorney of the US Department of Treasury’s Office of Tax Policy, commented that proposed amendments to Section 2704 (the IRS code that deals with valuation discounts) could be out by mid-September 2015.  While the IRS has yet to publish these amendments, they could be aimed at reducing and/or eliminating valuation discounts for lack of control and lack of marketability currently available to taxpayers gifting interests in family limited partnerships, closely-held companies, and other wealth transfer vehicles.

The IRS has tried for many years to limit these discounts through the Tax Court but has not won many victories and has been forced to attempt to go the legislative route to limit discounts.  President Obama’s 2013 budget (see page 79) included a proposal to restrict or eliminate valuation discounts on transfers of interests in family-controlled entities.  The IRS has not yet followed up on its plans to limit these discounts, creating uncertainty in the Estate Planning community.

Given the uncertainty around the future availability of valuation discounts, anyone with a potentially taxable estate should consult an estate planning attorney before the window passes.  According to IRS research, the larger the estate, the more likely the presence of a FLP.

Irs Valuation Discounts
Profile of 2004 estate tax decedents

Link to relevant article:

http://www.advfn.com/news_IRS-Takes-Aim-at-an-Estate-Planning-Strategy_67476977.html

Uncertainty Remains Around Irs Potential Treatment Of Valuation Discounts

Michael Conroy, CFA

DIRECTOR
mconroy@valuescopeinc.com

Mr. Conroy has more than 20 years of consulting and business valuation experience, concentrating on complex estate and gift valuation matters. He provides business valuation and financial consulting services to companies in a broad range of industries. Working with domestic and international clients, Mr. Conroy has performed thousands of business appraisals involving gift and estate tax, financial reporting, mergers, and acquisitions (valuations for buyers/sellers, fairness, and solvency opinions), litigation support, expert testimony, and other company requirements (including stock options and ESOPs). Mr. Conroy previously worked with the national valuation firm CBIZ Valuation Group, LLC here he was a senior manager. Prior to that, he taught chemistry and physics to high school and college students at Xavier College in Ba, Fiji, for two years as a U.S. Peace Corps volunteer.

 

Quarterly Economic Outlook: or when will bankruptcy attorneys get busy again?

Several quarters remain before bankruptcy attorneys return to high employment. However, weakness in specific sectors should provide an increased flow of near term bankruptcy activity.

Economic Outlook – Bankruptcy Attorneys

The current economic expansion is aging, but is likely to continue for several more quarters. The charts below provide insight into the economic outlook for the remaining duration of the current economic expansion.

Majority of Evidence – Signs of Stability

Economic Outlook - Bankruptcy Attorneys
Source: united states department of economic analysis at http://www. Bea. Gov/national/

The chart above illustrates our progress through the current business cycle and the length of the prior two cycles. The expansion in the 1990’s remains the longest in US history. The chart above indicates that real GDP growth for the four quarters ending June 2015 averaged a healthy 2.7%.

Economic Outlook - Bankruptcy Attorneys
Source: united states bureau of labor statistics at http://data. Bls. Gov/timeseries/lns14000000

Unemployment remains low (see chart above), while inflation remains under control (see chart below).

Economic Outlook - Bankruptcy Attorneys
Source: federal reserve bank of minneapolis at https://www. Minneapolisfed. Org/community/teaching-aids/cpi-calculator-information/consumer-price-index-and-inflation-rates-1913; note that the fed has targeted a 2. 0% inflation rate in recent years

The strong US dollar, weak oil and commodity prices and weak global growth are the primary contributors to today’s low inflation rate. Low inflation has allowed the Federal Reserve (the “Fed”) to leave the fed funds rate close to 0% for seven years.

Economic Outlook - Bankruptcy Attorneys
Source: united states federal reserve board at http://www. Federalreserve. Gov/releases/h15/data. Htm

The chart below shows the Fed raised the fed funds rate to fight inflation before each of the last two recessions. In this chart, corporate earnings are a proxy for economic growth. The Fed has not begun the tightening cycle which precedes business contractions.

Economic Outlook - Bankruptcy Attorneys
Correlation between corporate earnings and fed funds rate

The yield curve remains a reliable predictor of the approach of the end of economic expansions.

Economic Outlook - Bankruptcy Attorneys
Source: m. G. J, “the imf urges the fed to delay a rate rise”, the economist, september 3, 2015

The yield curve represents the yield on US Treasury obligations of various maturities. The Fed raises short-term interest rates to reduce the current inflation rate. This effort consistently results in a circumstance where short-term rates rise to yields considered appropriate for long-term Treasury bonds in the final stages of economic expansions.

Minority of Evidence – Signs of Instability

The weak global economy has resulted in weak commodity prices, particularly weak oil prices.

Quarterly Economic Outlook: Or When Will Bankruptcy Attorneys Get Busy Again?
Source: us energy information administration at http://www. Eia. Gov/dnav/pet/pet_pri_spt_s1_d. Htm

The weakness in oil prices has caused corporate earnings weakness for the last three quarters.

Economic Outlook - Bankruptcy Attorneys
Source: standard & poors corporation https://us. Spindices. Com/search/? Query-s%26p+500+earnings&search=go&search=go – “index earnings”

In the manufacturing sector, growth has almost slowed to contraction.

Economic Outlook - Bankruptcy Attorneys
Source: national association of purchasing managers – manufacturers’ purchasing managers’ index

Energy sector weakness has a negative impact on companies that borrowed heavily when oil prices were expected to remain high.

Increasing distress in the energy sector has caused yields on syndicated loans to increase 100 basis points from May 2015.

Economic Outlook - Bankruptcy Attorneys
Source: yield on leveraged loan 100 index at http://www. Leveragedloan. Com

Similarly, more than $5.2 billion in funds have been removed from the loan market since mid-July.

Economic Outlook - Bankruptcy Attorneys
Source: funds flow from syndicated loan market at http://www. Leveragedloan. Com

Conclusion

Several quarters remain before bankruptcy attorneys return to high employment. However, weakness in specific sectors should provide an increased flow of near term bankruptcy activity.

Footnotes

[1] Source: United States Department of Economic Analysis at http://www.bea.gov/national/

[2] Source: United States Bureau of Labor Statistics at http://data.bls.gov/timeseries/LNS14000000

[3] Source: Federal Reserve Bank of Minneapolis at https://www.minneapolisfed.org/community/teaching-aids/cpi-calculator-information/consumer-price-index-and-inflation-rates-1913; note that the Fed has targeted a 2.0% inflation rate in recent years

[4] Source: United States Federal Reserve Board at http://www.federalreserve.gov/releases/h15/data.htm

[5] Source: Standard & Poors Corporation at http://us.spindices.com/search/?query-S%26P+500+earnings&Search=GO&Search=GO – “Index Earnings” spreadsheet, Quarterly Data tab

[6] Source: United States Federal Reserve Board at http://www.federalreserve.gov/releases/h15

[7] Source: M.G.J, “The IMF Urges the Fed to delay a rate rise”, The Economist, September 3, 2015

[8] Ibid

[9] Source: US Energy Information Administration at http://www.eia.gov/dnav/pet/pet_pri_spt_s1_d.htm

[10] Source: Standard & Poors Corporation at http://us.spindices.com/search/?query-S%26P+500+earnings&Search=GO&Search=GO – “Index Earnings” spreadsheet, Quarterly Data tab

[11] Source: National Association of Purchasing Managers – Manufacturers’ Purchasing Managers’ Index

[12] Source: Kakouris, Rachelle, “Oil & Gas Cos Could See 40% Decline in Borrowing Base – Survey”, September 23, 2015 at www.leveragedloan.com/category/distressed-debt/

[13] Source: Yield on Leveraged Loan 100 Index at http://www.leveragedloan.com

[14] Source: Funds flow from syndicated loan market at http://www.leveragedloan.com

Christopher C. Lucas, CFA, CPA

PRINCIPAL
clucas@valuescopeinc.com
Full Bio →

 

BREAKING: Tuomey will pay U.S. $72.4 million to duck $237 million False Claims verdict

Tuomey Healthcare System has agreed to pay $72.4 million to settle its case with the U.S. government regarding illegal compensation arrangements with doctors.

Tuomey will pay 72 million

Tuomey Will Pay 72 Million has agreed to pay $72.4 million to settle its case with the U.S. government regarding illegal compensation arrangements with doctors. A federal jury found in 2013 that Tuomey had violated the False Claims Act by submitting tens of thousands of illegal claims to Medicare in which doctors were being compensated for referring patients, which is a violation under the Stark Law. Tuomey agreed to the settlement after suffering three defeats in federal court.

The settlement amount is less than a third of $237 million penalty determined by a federal appeals court. The original verdict would have been the largest penalty levied against a community hospital and would have exceeded Tuomey’s annual revenue. Tuomey is a not-for-profit system with its largest facility being the only hospital in Sumter, South Carolina. However, the settlement includes that Tuomey will be sold to Palmetto Health based in Columbia, South Carolina. Tuomey had indicated its intent to partner with Palmetto prior to the settlement.

The case against Tuomey originated from Dr. Michael Drakeford, who declined to enter an agreement with the hospital. Dr, Drakeford will receive $18.1 million from the settlement as whistle blowers are entitled to receive a percentage of the penalty in successful False Claims Act cases.

Breaking: Tuomey Will Pay U.s. $72.4 Million To Duck $237 Million False Claims Verdict

Brent Shockley

SENIOR MANAGER
bshockley@valuescopeinc.com

 

Tuomey will pay U.S. $72.4 million to duck $237 million False Claims verdict

Fed’s Dudley Says U.S. on Track for 2015 Interest-Rate Increase

Sept 2015 Interest Rate Increase

http://www.bloomberg.com/news/articles/2015-09-28/fed-s-dudley-says-u-s-on-track-for-2015-interest-rate-increase

Sept 2015 Interest Rate Increase“The economy is doing pretty well,” Dudley said Monday at an event hosted by the Wall Street Journal in New York. “My expectation is that we probably will raise interest rates later this year.”

Dudley said he expected growth in the second half will be a little bit weaker than in the first half, when the U.S. grew around 2.25 percent on an annualized basis.

Concern over the outlook for the world’s second-largest economy have roiled financial markets since China’s surprise currency devaluation on Aug. 11. Investors have reduced their bets the Fed would act at one of its two remaining FOMC meetings this year and saw a 40 percent probability of a move by the Dec. 15-16 FOMC, down from 49 percent on Sept. 21.

Christopher C. Lucas, CFA, CPA

PRINCIPAL
clucas@valuescopeinc.com
Full Bio →

 

PRESS RELEASE: U.S. Court of Federal Claims Concurs with ValueScope Expert’s Opinion in Russian Recovery Fund

Southlake, Texas, August 19, 2015:

In a decision for the United States, the U.S. Court of Federal Claims disallowed tax losses claimed by an affiliate of the Russian Recovery Fund in an unusual and complex tax shelter case.

Facts
The primary actors in the case are three hedge funds:

Tiger Management affiliated funds (“Tiger”) – an independent third party
Russian Recovery Fund (the “RRF”) – the plaintiff
FFIP – the taxpayer and a hedge fund affiliated with the RRF

In 1999, Tiger contributed more than 3.0 billion rubles of Russian debt instruments to the RRF as an in-kind contribution for RRF shares. Although the fair market value of the contribution approximated $15 million, Tiger’s tax basis in the contributed assets exceeded $230 million. Two weeks later, Tiger sold its RRF shares to FFIP for $14.1 million.

The high-level economics of the tax case are illustrated below:

Unlike other tax shelter cases, the RRF case was significantly more complex because the contributed securities generated significant economic returns and had economic substance. Debt typically contributed to Distressed Asset Debt (“DAD”) tax shams involves high basis debt instruments on which little or no value is ever recovered.

The Court’s Opinion
Through the facts of the case and the testimony of its expert witnesses, the U.S. Department of Justice (“DOJ”) demonstrated that Tiger’s in-kind contribution was a disguised sale. They also demonstrated that the RRF’s fund manager was aware that Tiger was a seller of Russian debt rather than an intentional investor in RRF, as the Taxpayer claimed.

The Court found the expert opinions of Chris Lucas, ValueScope Director, to be helpful, citing his testimony 16 times in its opinion, including:
“[Mr. Lucas’] primary opinion was that RRF was structured more as a tax shelter than as a legitimate hedge fund.”

The Court agreed with Mr. Lucas’ expert testimony:

“…that the losses claimed by RRF ($223 million in total) are so disproportionate to its investment in Tiger assets (roughly $14 million) as to be unreasonable. We found Mr. Lucas to be a persuasive and knowledgeable witness.” (page 22)

Mr. Lucas helped the Court appreciate the unreasonableness of the economics claimed by the Taxpayer based on its argument that it had made an at-risk investment in Russian debt. The Court saw through this, however, and realized that FFIP was attempting to earn a large, riskless profit from the US government with significant potential economic upside.

The Court reviewed the facts and concurred with Mr. Lucas’ testimony:

“Our conclusion that Tiger was never a real partner in RRF is arguably sufficient by itself to undo the loss carryover. We would not recognize the transaction as anything other than a sale because that is what Tiger intended it to be. However, there is a massive amount of circumstantial evidence that the RRF was aware early on that Tiger had no real interest in becoming a partner, and was a willing participant at some point in facilitating the transfer of assets through the sham partnership.” (page 35)

About ValueScope, Inc.
ValueScope, Inc. is one of the nation’s foremost experts in complex federal tax matters.  ValueScope’s Principals and Directors are called upon to testify regularly in U.S. Tax Court and Federal District Courts.  Its team includes experienced valuation experts, management consultants, Chartered Financial Analysts, Certified Public Accountants, PhD’s, statisticians and creative and strategic thinkers.* ValueScope develops sophisticated financial and econometric analyses to support our clients’ needs for litigation support, financial reporting, tax reporting, management consulting, transaction advisory, and other needs.

*ValueScope is not a licensed CPA firm.