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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.

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

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.

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.

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.

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.

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.

Amazon.com, Inc. v. Commissioner

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.

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.”

Exelon Corp. v. Commissioner

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.

Devoid of Goodwill, Corporation Escapes Income Tax Liability

Tax Court says taxpayer’s company owned no corporate goodwill and had no right to taxpayer’s personal goodwill and, therefore, was not liable under IRC Sect. 311(b)(1); the taxpayer, in turn, was not liable for gifting corporate goodwill to his sons.

Absent Appearance by Appraiser, Valuation Report Is Hearsay

In an income tax case where the IRS challenges the calculation of net unrealized built-in gain that has been based on a contemporaneous valuation of the assets subject to built-in gain tax, the valuation report by itself constitutes inadmissible hearsay where the preparing appraiser is not available for cross-examination.

Van Der AA Investments, Inc. v. Commissioner

In an income tax case where the IRS challenges the calculation of net unrealized built-in gain that has been based on a contemporaneous valuation of the assets subject to built-in gain tax, the valuation report by itself constitutes inadmissible hearsay w ...

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