by Royer Advisors | Dec 11, 2024 | Court Rulings, Valuations
Amazon.com, Inc. v. Commissioner Amazon scored a win against the Internal Revenue Service in a transfer pricing case. The dispute was over the calculation of buy-in payments to compensate Amazon US for the transfer of a group of intangibles to the company’s European...
by Royer Advisors | Dec 11, 2024 | Court Rulings
Horizon Health Corp. v. Acadia Healthcare Co The Texas Supreme Court issued an important opinion on future lost profits that illustrates how a damages analysis that has some support in the evidence may still fail to meet the legal standard of “reasonable certainty.”...
by Royer Advisors | Dec 11, 2024 | Court Rulings, Valuations
Estate of Koons v. Commissioner (Koons II) The 11th Circuit Court of Appeals upheld a 2013 Tax Court ruling in an estate and generation-skipping tax case that centered on the fair market value of a revocable trust’s interest in an LLC. The crux of the valuation was...
by Royer Advisors | Dec 11, 2024 | Court Rulings, Valuations
Bair v. Bair When confronted with quantifying the appreciation of non-marital property, it is common for valuators first to classify the change in value as “active” or “passive” and then do the valuation. A Florida case shows that, when applied prematurely, this...
by Royer Advisors | Dec 11, 2024 | Court Rulings, Valuations
Estate of Powell v. Commissioner Given the unfavorable optics of a recent case, the Tax Court’s finding that the value of assets transferred from the decedent to a family limited partnership was includible in the value of the decedent’s gross estate is not...
by Royer Advisors | Dec 11, 2024 | Court Rulings
The recent Wayfair decision by the U.S. Supreme Court has had a major impact on states that want to collect sales and use taxes. Before this case, economic “nexus” for tax purposes was established only if the seller of goods or services exhibited a “physical presence”...