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9th Circuit Upholds Tax Court’s Valuation of Intangibles in Big Transfer Pricing Case

Appeals court affirms Tax Court ruling favoring taxpayer’s CUT method over IRS’ DCF to value various intangible assets transferred to European subsidiary; governing regulations limit definition of “intangible” to independently transferrable assets, excluding residual business assets, court says.

Amazon.com, Inc. v. Commissioner (II)

Appeals court affirms Tax Court ruling favoring taxpayer’s CUT method over IRS’ DCF to value various intangible assets transferred to European subsidiary; governing regulations limit definition of “intangible” to independently transferrable assets, excluding residual business assets, court says.

CUT Method Prevails in Amazon’s Transfer Pricing War With IRS

In transfer pricing case, Tax Court says Amazon more accurately determined buy-in and cost-sharing payments by using CUT method to value separately three types of intangible assets; IRS’s DCF analysis results in improper enterprise valuation, court says ...

CUT Method Prevails in Amazon’s Transfer Pricing War With IRS

In transfer pricing case, Tax Court says Amazon more accurately determined buy-in and cost-sharing payments by using CUT method to value separately three types of intangible assets; IRS’s DCF analysis results in improper enterprise valuation, court says.

Amazon.com, Inc. v. Commissioner (I)

In transfer pricing case, Tax Court says Amazon more accurately determined buy-in and cost-sharing payments by using CUT method to value separately three types of intangible assets; IRS’s DCF analysis results in improper enterprise valuation, court says.

Expert’s Evidence Is Key to Reversing a Zero Damages Verdict

Texas Court of Appeals enforces a ten-year non-compete agreement as to an owner selling a business; it also reverses a jury award of zero lost profits damages after finding the plaintiff’s expert offered reliable evidence of lost customer contracts and sa ...

Heritage Operating, LP v. Rhine Bros. LLC

Texas Court of Appeals enforces a ten-year non-compete agreement as to an owner selling a business; it also reverses a jury award of zero lost profits damages after finding the plaintiff’s expert offered reliable evidence of lost customer contracts and sa ...

Analysts Not Required to Predict the Future—Only to Probe Present Facts

In assessing fair value and adequate consideration of ESOP transaction, court considers whether appraiser should have reasonable foreseen future events affecting stock and company value.

Keach v. U.S. Trust Co.

In assessing fair value and adequate consideration of ESOP transaction, Court considers whether appraiser should have reasonable foreseen future events effecting stock and company value.

Delaware block method not appropriate for marital dissolution; valuation that considers multiple factors prevails

The primary issues in this marital dissolution were whether the trial court used a proper methodology in valuing the parties’ business, International Book Import Service Inc.

Kerce v. Kerce

Issue was the valuation of the parties' book import business, and the proper methodology for determining value.

No Evidence That Board's Financial Advisor Was Fiduciary to ESOP

This was a motion for summary judgment in connection with an action for breach of fiduciary duty to the employee stock ownership plan (ESOP) of F&G company.

Lord's & Lady's Enterprises v. John Paul Mitchell Systems

The Massachusetts Court of Appeals reversed the lower court's award of compensatory damages in this breach of contract action.

Damages for Breach of Contract Must Be Foreseeable by the Parties When They Make the Contract

The Massachusetts Court of Appeals reversed the lower court's award of compensatory damages in this breach of contract action.

IRS Contends License Payments 'a sham'

The ultimate issue in this case is whether taxable gifts or constructive dividend income were received by the son of the controlling shareholder of Home Shopping Network (HSN), through Pione ...

Speer v. Commissioner

At issue is the valuation of a software licensing company for federal income and gift tax purposes.

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