Key to gauging the validity of any tax-related vehicle is a transaction analysis of its intended business purpose. We have undertaken many such assessments, in which we examined whether the investment instrument in question (excluding any fees associated with its transaction) had a reasonable upside relative to other potential investments.
For example, an option may be purchased for ostensibly legitimate business reasons. Our experts evaluate the option’s potential profitability and take into account any related hedging benefits to determine if there is an adequate business purpose associated with the option as an investment.
Our rigorous transaction analysis draws on expertise in:
- Valuation, especially of complex derivative instruments
- The mechanisms underlying various tax shelters, including sale leasebacks and other instruments related to artificial investment loss
- Analysis of market dynamics
- Accounting and financial statements
- Featured Expert Laurits R. Christensen Managing Principal, Denver
- Featured Expert R. Glenn Hubbard Dean Emeritus, Russell L. Carson Professor of Finance and Economics, Columbia Business School
Chemtech Royalty Associates L.P. v. United States of America
AWG Leasing Trust v. United States of America
- Featured Expert Thomas Lys Eric L. Kohler Emeritus Chair in Accounting and Professor of Accounting Information & Management, Kellogg School of Management, Northwestern University; Professor of Law (by courtesy), Northwestern University Law School
Palm Canyon X Investments LLC, AH Investment Holdings, Inc., Tax Matters Partner v. Commissioner of Internal Revenue Service