both having reasonable knowledge of all relevant facts and neither being under any compulsion to buy or sell.” Caracci v. Comm’r, 456 F.3d 444, 456 (5th Cir.2006) (per curiam). The “willing buyer and seller are hypothetical persons rather than specific individuals or entities, and their characteristics are not necessarily shared by the' actual seller or particular buyer.” Id. Nevertheless, “the valuation method must take into account, and correspond to, the attributes of the entity whose assets are being valued.” Id.; see also Eyler, 88 F.3d at 451 (applying test in ESOP context). In addition to equitable restitution, courts have broad equitable authority to award a surcharge in the amount of rescinded transactions. See Gearlds v. Entergy Servs., Inc., 709 F.3d 448, 451 (5th Cir.2013) (<HOLDING>). A plaintiff may seek surcharge even when it
holding that  an award of makewhole relief in the form of surcharge was within the scope of appropriate equitable relief for purposes of  502a3 quoting cigna corp v amara  us  131 sct 1866 1880 179 led2d 843 2011 holding that claims for equitable relief under  502a3 are only available when a plaintiff has no other relief under erisa holding that ylsts look through doctrine survives harrington v richter  us  131 sct 770 178 led2d 624 2011 holding that equitable relief under  502a3 does not include compensatory and punitive damages holding that  1132a3b authorizes the award of appropriate equitable relief to a beneficiary for violations of erisa