by Royer Advisors | Dec 11, 2024 | Court Rulings, Deductions, IRS Regulation
The IRS recently announced its “nonacquiesence” with a federal appeals court decision that held a retailer that issued loyalty discounts to its customers was entitled to deduct its liabilities attributable to discounts, which were accrued but hadn’t...
by Royer Advisors | Dec 11, 2024 | Court Rulings, Valuations
Lane v. Lampkin, 2015 Miss. LEXIS 503 (Oct. 8, 2015) (Lampkin II) It’s not uncommon for a trial court to decide a valuation issue by “splitting the baby”—that is, reaching a compromise somewhere in the middle of the opposing figures. Often the decision, however...
by Royer Advisors | Dec 11, 2024 | Court Rulings, Valuations
In re Mercury Cos., 2015 Bank. LEXIS 3443 (Oct. 9, 2015) (In re Mercury II) After filing for Chapter 11 bankruptcy, the plaintiff claimed the sale of certain subsidiaries to the defendant entities was an avoidable fraudulent transfer. The Bankruptcy Court considered...
by Royer Advisors | Dec 11, 2024 | Court Rulings, Financial Planning, IRS Regulation, Tax Planning
Generally, corporations can deduct interest on debts for federal tax purposes, and a valid obligation exists if the parties intended to create a debt, and the debt is enforceable and unconditional. A capital contribution, in contrast, is a direct or indirect...
by Royer Advisors | Dec 11, 2024 | Court Rulings, Valuations
Merion Capital LP & Merion Capital II LP v. BMC Software, 2015 Del. Ch. LEXIS 268 (Oct. 21, 2015) Don’t second-guess the result of a robust, arm’s-length sales process! That’s the view the Delaware Court of Chancery has been taking lately in statutory appraisal...
by Royer Advisors | Dec 11, 2024 | Business Plans, Court Rulings, IRS Regulation, Tax Planning, Tax Preparation
If you are an employee, a partner, a partner who doesn’t know it, or a combination of these classifications, there may be serious tax implications. Here are some recent developments that you need to know if you participate in a business that’s operated as...
