This panel presentation will focus on the following topics:
- Identifying when and under what circumstances Stark applies
- Organization of facts critical to formulating the analysis
- Navigating and tying agreements to substantive Stark exceptions
- What are the common exceptions?
- Recent revisions to Stark
- defining an “entity”
- “per click”
- Calculating Fair Market Value
- Sources
- Tabulating and assigning value within the context of the situation and for the locality
- How do you determine whether an agreement completely fits an exception?
- The danger of being too conservative
- Ensuring a commercially reasonable business rationale
- Meeting the technical requirements of Stark provisions
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