The Michel-Shaked Group’s Israel Shaked (Managing Director) and Paul Dionne (Manager) discuss what quantitative bankruptcy prediction models are and how the discretion given to the financial expert applying these methodologies can lead to the abuse of the models in both bankruptcy and tax litigation settings....
In August 2018, the United States Tax Court filed its opinion on Illinois Tool Works Inc. & Subsidiaries (Petitioner) v. Commissioner. The Court ruled in favor of the Petitioner on all issues and determined that the intercompany loans were bona-fide debt for tax purposes....
In May 2018, the United States Tax Court issued an opinion in Dynamo Holdings Limited Partnership (Petitioner) vs. Commissioner, determining that related party loans were in fact debt. The Court found the Petitioner’s experts, Professor Israel Shaked and Dr. Bill Chambers of the Michel-Shaked...
In part-two of their article published in the April 2018 edition of Thomson Reuter’s Journal of Taxation, The Michel-Shaked Group’s Israel Shaked and Paul Dionne illustrate the work the authors performed and trial testimony that was provided in NA General Partnership vs. Commissioner tax case...
Numerous academic articles have examined when and under what circumstances related party debt, (e.g. indebtedness issued by one member of a consolidated corporate group to another), may be considered valid debt for tax purposes. Recently, the Michel-Shaked Group’s Israel Shaked (Managing Director) and Paul...