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....
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 Group “credible and helpful in deciding these cases.”...
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 (ScottishPower)....
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....
The valuation of relatively healthy companies involves many unknowns. However, the valuation of distressed companies includes additional elements of uncertainty. The Michel-Shaked Group’s Israel Shaked (Managing Director) and Brad Orelowitz (Senior Vice President) published an article in the Jan/Feb 2018 issue of the TMA’s Journal of Corporate Renewal discussing key valuation issues in distressed investing....
Our Managing Director, Israel Shaked, recently presented at the Institutional Investor’s Global Shareholder Activism Conference, co-sponsored by Grant & Eisenhofer. Dr. Shaked's presentation addressed the increased distress among retailers and the role played by private equity firms. He discussed the possibility of the potential increase in fraudulent conveyance claims resulting from leveraged recapitalizations....