Insiders Examine Michael Jackson Estate Valuation Dispute
Testifying experts for the estate give their main takeaways from this fierce dispute with the IRS.
BV News and Trends August 2021
A monthly roundup of key developments of interest to business valuation experts.
Benchmarking Identifiable Intangibles and Their Useful Lives in Business Combinations
Join Ray Rath for key insights on the determination of the economic and useful (amortization) lives for intangible assets. The course provides an overview of key accounting guidance pertaining to the valuation of intangible assets. A detailed focus on the estimation of an economic life for intangible assets is included. The event will also include insights on industry-specific factors impacting the valuation and economic lives of different types of intangible assets. A discussion of purchase ...
Prince estate valuation featured on latest AICPA podcast
In the shadow of the recent court decision in the Michael Jackson estate valuation dispute, the estate of pop star Prince is currently locked in a fierce estate and gift tax dispute.
Michael Jackson estate valuers give rare inside look
Experts for the estate of pop superstar Michael Jackson presented a fascinating look at how the valuations were done for the “tax trial of the century” in a BVR webinar.
Interesting question on the Michael Jackson case
There were three main valuation matters in the case of the Michael Jackson estate versus the IRS, and the estate prevailed in two of them (see our most recent coverage here).
Michael Jackson case featured on BVR ‘power panel’ July 27
Experts involved in the high-profile case involving the Michael Jackson estate versus the IRS will discuss the contentious valuation issues in the case during a BVR webinar, Power Panel: Estate of Michael J. Jackson v. Commissioner.
In Jackson case, Tax Court dismisses IRS expert’s revenue projections as ‘simply not reasonable’
When Michael Jackson died, his image and likeness was besmirched, and yet, once competent executors took charge, they were able to make a lot of money for the estate in the immediate post-death years.
Business Combinations and Fair Value for Financial Reporting
Are you confused by business combinations? Join William Kennedy for this engaging session covering GAAP fair value standards and their application in business combinations. Hear a discussion of the nuances of the GAAP fair value standard and history of how it was developed as part of the GAAP-IFRS convergence project. Also learn how the valuation approaches and methods used in fair value assessment differ from valuation approaches used in a fair market value appraisal.
Tax Court resists tax affecting in Michael Jackson case
Although the U.S. Tax Court recently handed the Michael Jackson estate a decisive victory regarding the estate’s tax liability, the court did not side with the estate on tax affecting, an issue that has preoccupied valuators, many of whom are proponents of the practice, for a long time.
Tax Court issues highly anticipated ruling in Michael Jackson case
In the long-running litigation between the estate of the late megastar Michael Jackson and the Internal Revenue Service, the U.S. Tax Court finally issued its opinion on the value of Jackson’s name and likeness, as well as the value of his interest in two music publishing assets.
Estate of Michael J. Jackson v. Commissioner
Tax Court mostly sides with estate of late superstar in valuing three contested assets; assets had to be valued separately, based on parties’ stipulations, and at death; court says Jackson’s “tattered” image and likeness meant he earned little money apart from his music; court rejects tax affecting.
Tax Court Hands Jackson Estate Major Win but Finds Reasoning for Tax Affecting Unpersuasive
Tax Court mostly sides with estate of late superstar in valuing three contested assets; assets had to be valued separately, based on parties’ stipulations, and at death; court says Jackson’s “tattered” image and likeness meant he earned little money apart from his music; court rejects tax affecting.
In Buyout Dispute, Appeals Court Finds There Was No Basis for Jury to Set Aside Appraisers’ Contractually Mandated Value Determination
In buyout dispute, appeals court reverses trial court’s judgment, finding it was based on jury’s erroneous decision to set aside a contractually mandated appraisal and provide its own buyout price; there was no indication the appraisers misinterpreted the controlling partnership agreement; court remands.
Parrish v. Schroering
In buyout dispute, appeals court reverses trial court’s judgment, finding it was based on jury’s erroneous decision to set aside a contractually mandated appraisal and provide its own buyout price; there was no indication the appraisers misinterpreted the controlling partnership agreement; court remands ...
BVU News and Trends March 2021
A monthly roundup of key developments of interest to business valuation experts.
Prince estate and IRS embroiled in fierce valuation dispute
A recent article in the Star Tribune says the executor of the estate of Prince, the late world-famous rock star, and the Internal Revenue Service are currently locked in a fierce estate and gift tax dispute.
Global intangible asset value rebounds to hit all-time high
Business valuers recognise that intangibles present individual ‘facts and circumstances’ challenges. And IFRS 3, even without the proposed amortisation changes, does not fully report the current value of acquired or created intangibles (increasing the operational value of intangibles is generally a strategic goal).
Coca-Cola Co. v. Comm'r
Coca-Cola had been applying a transfer pricing method called the 10-50-50 since it entered into a closing agreement with the IRS in 198, covering the years 1987 to 1995. Coca-Cola had consistently followed that transfer pricing method; the IRS had audited Coca-Cola annually and “signed off” on that transfer pricing method for over a decade. Upon examination of Coca-Cola’s tax returns for 2007 to 2009, the IRS determined that Coca-Cola’s transfer pricing methodology did not reflect arm’s-length norms because it overcompensated the supply point and undercompensated Coca-Cola. The IRS reallocated income between Coca-Cola and its supply points employing the comparable profits method (CPM) pursuant to Reg. Sec. 1.482-5. The IRS increased Coca-Cola’s taxable income by over $9 billion assessing over $3 billion in additional taxes!
2020’s Most Important Transfer Pricing Case—Coca-Cola
Coca-Cola had been applying a transfer pricing method called the 10-50-50 since it entered into a closing agreement with the IRS in 1986, covering the years 1987 to 1995. Coca-Cola had consistently followed that transfer pricing method; the IRS had audited Coca-Cola annually and “signed off” on that transfer pricing method for over a decade. Upon examination of Coca-Cola’s tax returns for 2007 to 2009, the IRS determined that Coca-Cola’s transfer pricing methodology did not reflect arm’s-length norms because it overcompensated the supply point and undercompensated Coca-Cola. The IRS reallocated income between Coca-Cola and its supply points employing the comparable profits method (CPM) pursuant to Reg. Sec. 1.482-5. The IRS increased Coca-Cola’s taxable income by over $9 billion assessing over $3 billion in additional taxes!
Valuation Challenges and Best Practices in Joint Ventures and Strategic Affiliations
Today, corporate investments into joint ventures and other non-controlled entities now exceed $5 trillion per year, according to Ankura/Water Street Partners' analysis of U.S. Government data. Companies utilize joint ventures for a variety of reasons, including to access capabilities, share risk, pool capital, secure added scale and scope, and satisfy regulatory requirements of local ownership. Join Jerry Chang, Molly Faber, and Tim Lubbe of Ankura to learn more about the increasing prevalence of joint ventures ...
Global BV News: Pretransaction PPAs increasing in GCC region, says Deloitte report
The growing importance of intangible assets has triggered an increased number of stakeholders from within the Gulf Cooperation Council (GCC) requesting a pretransaction purchase price allocation analysis, according to a new report from Deloitte Middle East in collaboration with the Saudi Authority for Accredited Valuers (TAQEEM).
IVSC interviews European Financial Reporting Advisory Group on new intangibles reporting issues and other topics
The new interview on the interaction between European views on IASB standard-setting and the valuation professions is now available from IVSC.
Refinitiv and S&P Global both enhance sustainability ‘ESG’
The two big financial data providers, Refinitiv and SPGI, released improvements to their methodologies to score listed company performance across social value themes including emissions, environmental product innovation, diversity and inclusion, human rights, and shareholder access.
More Ups and Downs for Patent Valuations in the UK and Beyond
Business valuers can expect further changes in the UK landscape for intellectual property (IP) creation and commercialization. Intangibles now represent almost 90% of the market value of the largest listed companies, so these changes may be the most significant factor in many current business valuations.