Expand the following panels for additional search options.

Willamette focuses on tax and transfer pricing

Taxation-related valuation and transfer pricing issues are the focus of summer 2021 Insights from Willamette Management Associates.

Tax Court deals another blow to cannabis dispensaries

In recent years, numerous cannabis businesses that are legal under state law have unsuccessfully challenged section 280E of the Internal Revenue Tax Code, which prohibits tax deductions for a business that “consists of” trafficking in a controlled substance.

In tax refund case, expert identifies only viable method to value stock in ‘severely distressed’ private company

The taxpayer sued the federal government for a refund, arguing she had overpaid income taxes on stock she had received as part of settling a lawsuit against her former employer.

Lucero v. United States

In tax case, court approves refund, finding value of unlisted stock in distressed closely held company that taxpayer received as part of a settlement was less than stated in settlement agreement; taxpayer’s expert showed market value approach was only suitable method to calculate fair market value.

Court Adopts Taxpayer Expert’s Method to Value Unlisted Stock of ‘Severely Distressed’ Company

In tax case, court approves refund, finding value of unlisted stock in distressed closely held company that taxpayer received as part of a settlement was less than stated in settlement agreement; taxpayer’s expert showed market value approach was only suitable method to calculate fair market value.

How would a wealth tax impact business valuation?

The FT ran a long interview with Gus O’Donnell last week, saying that ‘a UK wealth tax is more likely than ever because of the reordering of politics caused by the coronavirus pandemic.’

BVU News and Trends December 2019

A monthly roundup of key developments of interest to business valuation experts.

Details of the CUT method used in the Amazon case

Last week’s BVWire covered the 9th Circuit decision in the Amazon case that affirmed the U.S. Tax Court’s 2017 decision in favor of the company in a transfer pricing case.

Tax Court’s Amazon valuation ruling stands up to 9th Circuit scrutiny

The 9th Circuit recently affirmed the U.S. Tax Court’s 2017 decision in favor of Amazon in this key transfer pricing case, finding the governing regulations limited the definition of “intangible” to independently transferrable assets.

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.

Zausch v. Schnakenburg

Appeals court upholds trial court’s upward adjustment of father’s child support obligation based on a significant improvement in his economic circumstances; trial court followed applicable case law when calculating income related to father’s minority interests in several pass-through entities.

Indiana Court Upholds Child Support Calculation Involving Pass-Through Entities

Appeals court upholds trial court’s upward adjustment of father’s child support obligation based on a significant improvement in his economic circumstances; trial court followed applicable case law when calculating income related to father’s minority interests in several pass-through entities.

Tax Court’s Exelon ruling, turning on compromised appraisals, withstands appeal

In 2016, Tax Court Judge Laro ruled on the legitimacy of a series of Section 1031 transactions involving Exelon, an Illinois-based energy giant.

Appeals Court Upholds Tax Court’s Section 1031 Decision Pivoting on ‘Tainted Appraisals’

Appeals court upholds Tax Court’s ruling that taxpayer’s transactions do not represent section 1031 like-kind exchanges because taxpayer never assumed ownership of replacement plants; improper input from taxpayer’s law firm tainted appraisals used to show otherwise; accuracy penalty is justified.

Exelon Corp. v. Commissioner

Appeals court upholds Tax Court’s ruling that taxpayer’s transactions do not represent section 1031 like-kind exchanges because taxpayer never assumed ownership of replacement plants; improper input from taxpayer’s law firm tainted appraisals used to show otherwise; accuracy penalty is justified.

Tax Effects Are Relevant to Equitable Distribution Analysis

Reviewing court says in valuing owner spouse’s auto transport business and performing equitable distribution analysis, trial court erred when it refused to consider tax effects of potential sale of business before assigning asset to owner; case remanded.

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 ...

Carney v. Carney

Reviewing court says in valuing owner spouse’s auto transport business and performing equitable distribution analysis, trial court erred when it refused to consider tax effects of potential sale of business before assigning asset to owner; case remanded.

Tax Effects Are Relevant to Equitable Distribution Analysis

Reviewing court says in valuing owner spouse’s auto transport business and performing equitable distribution analysis, trial court erred when it refused to consider tax effects of potential sale of business before assigning asset to owner; case remanded.

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.

Compromised Asset Appraisals Undo Like-Kind Tax Plan

Tax Court says taxpayer’s transactions fail to meet Section 1031 requirements for income tax deferral; legal advisor’s ongoing interference with appraisal process compromised asset appraisals undergirding transactions to the point they became “useless.”

Key Tax Ruling From Ohio Supreme Court Concerning Pass-Through Entity

Ohio Supreme Court says tax provision imposing state income tax on capital gain realized by nonresident investor in pass-through entity violates taxpayer’s due process rights barring showing taxpayer’s activities are “unitary with” those of the business.

Compromised Asset Appraisals Undo Like-Kind Tax Plan

Tax Court says taxpayer’s transactions fail to meet Section 1031 requirements for income tax deferral; legal advisor’s ongoing interference with appraisal process compromised asset appraisals undergirding transactions to the point they became “useless.”

1 - 25 of 91 results