New case

At every development gate an asset carries two values: V_keep, the value of retaining and developing onward under our own beliefs and economics, and V_sell, what a generic outside buyer would pay under theirs, net of the buyer's surplus wedge. The spread is the trade rationale — positive means the asset is worth more to someone else than to us at that gate. Figures are at the gate, not discounted back to today. Switch to After-tax for the same curves net of corporate tax (Section 174 capitalization, NOL carryforward, FDII on foreign revenue, R&D / orphan credits, capital-gains rate on sale).

Stage-valuation Monte Carlo is run per asset, independently of the portfolio correlation plan. The default buyer profile is a generic moderately-competitive large-pharma acquirer; the default tax profile is a U.S.-headquartered C corp under 2026 rules. Both are editable assumptions, not recommendations about whether to transact. The model captures revenue uplift, cost efficiency, strategic-synergy premium, the buyer's wedge, an optional buyer WACC override, and standalone-asset corporate tax (Section 174 capitalization with 5y US / 15y foreign amortization, NOL carryforward with 80% offset cap, FDII at 16.4% on foreign-source revenue, Section 41 / Section 45C credits, and capital gains on disposition). It does not yet capture: stage-conditional changes in strategic value, winner's-curse premiums in competitive auctions, POS asymmetry between an experienced acquirer and an unproven seller, GILTI / foreign-subsidiary IP structuring, Section 382 NOL limits, installment-sale / CVR treatment of contingent payments, R&D credit carryforward, or portfolio-level NOL pooling across assets. After-tax curves assume a clean-slate tax position at each gate (no implicit credit from pre-gate spending on this asset). Override starting_nol_balance and capital_gains_rate_on_sale on the tax profile to reflect a specific engagement.