Insights

In a bankruptcy, financial projections play a significant role in many different aspects of the process. In many cases, the Court’s preference is to rely on management’s projections, as management usually has vast experience within the company. However, there are instances where projections produced by a company’s management are not reliable....

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. Michel-Shaked Group's experts represented the Petitioner....

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 Dionne (Senior Analyst) published an article in Thomson Reuter’s Journal of Taxation March 2018 issue, which takes a different approach than those that have come before it....