• Litigation Consulting - QuickRead Featured

    The Income Tax Treatment of Economic Damages Awards

    Part 1: The Income Tax Treatment of Personal Economic Damages Awards Financial experts are frequently asked about the tax impact of damage awards, both paid and received. The complexities of the Internal Revenue Code (“IRC”) and judicial interpretations thereof make determining the taxability of receipts or payments difficult. The same is true when dealing with the taxability of economic damages awarded to plaintiffs in civil actions. Nuances in the IRC and the judicial interpretations may make it difficult for a taxpayer to determine the taxability of his or her proceeds from a litigation award of personal economic damages. Whether or…

  • Financial Forensics - Litigation Consulting - QuickRead Featured

    Lost Profits versus Lost Business Value

    Differences Between the Two Values Damages remedies often focus on lost profits and lost business value, with such remedies typically calculated by financial experts. There continues to be a trend in the courts to preclude experts from testifying, or to disregard them altogether because their opinion does not meet the reasonable certainty standard. Either of these outcomes can be a devastating result for the client. These results occur, in part, from a lack in understanding of the proper calculation of lost profits or lost value. A relevant and reliable opinion, able to withstand the court’s scrutiny in litigation, needs to…

  • Litigation Consulting - QuickRead Featured

    Evaluating the Valuation Expert

    Challenges and the Emergence of Peer Review Judges are often required to pick apart complicated expert analysis to assess the validity and reliability of an expert’s work when its admissibility is challenged. But in the professional domain, we would not expect a tax auditor to be able to analyze a report on macroeconomic theory. Why, then, do we ask courts to perform these analyses in fields from accounting to zoology? It stands to reason our courts need help. We propose that litigators and experts now have the chance to help courts, and in the process, serve their clients better. Litigators…

  • Litigation Consulting - QuickRead Featured - QuickRead Top Story

    Transitioning the Financially Inexperienced Divorce Client to Self-Sufficiency

    The Emergence of the Transitional Support Advisor Following a divorce, how does a financially naïve former spouse transition to become a financially independent former spouse? In this article, the author discusses what is a Transitional Support Expert and that professional’s role in a dissolution proceeding and following entry of the decree.

  • Litigation Consulting - QuickRead Featured - QuickRead Top Story

    Reasonable Certainty in Lost Profits Calculations

    Prepare, Verify, and Excel at Trial In order to recover lost profits in a commercial damage case, three standards must be met. First, plaintiff must show proximate cause; second, the foreseeability; and third, reasonable certainty. This article will focus on the third standard, reasonable certainty. Experts seeking to provide realistic lost profit estimates must be aware of this standard. The following discussion will review literature, court decisions, and practical efforts that may assist experts in addressing reasonable certainty.

  • Litigation Consulting - QuickRead Featured - QuickRead Top Story

    Taking a Deeper Look into Momentive, Part 1

    Secured Creditors Lost Almost $200 Million in Economic Value Due to the Imposition of Below Market Interest Rates Many bankruptcy practitioners have focused on the recent decisions in Momentive[1] that forced secured creditors to refinance prepetition loans at below market interest rates.  Most of these practitioners’ publications focus on the courts’ findings and the potential implication on future matters.

  • Litigation Consulting - QuickRead Featured - QuickRead Top Story

    Discount Rates

    The Present Value of Future Lost Profits, and the Time Value of Money Experts estimating the present value of a business’ future lost profits have much less direction from the courts than their counterparts estimating the present value of a person’s lost earning capacity. Professional literature has attempted to fill this gap providing many articles discussing the differing methods for analyzing lost profits (e.g., yardstick, before-and-after, but for) or how to determine the discount rate by applying a weighted cost of average capital, equity rates of return, or some form of risk premium build-up. This article moves away from these…

  • Litigation Consulting - QuickRead Featured - QuickRead Top Story - Valuation/Appraisal

    Separating Personal Goodwill from Entity Goodwill in the Closely Held Company Valuation

    Guidance from Bross Trucking v. Commissioner (2014) Valuation analysts often have to separate company-owned entity goodwill from shareholder-owned personal goodwill in the valuation of closely held companies. These valuations may be performed for family law, shareholder dispute, breach of contract, or other litigation purposes; for transaction structuring and sale consideration allocation purposes; and for gift tax, estate tax, or income tax purposes.

  • Litigation Consulting - Mergers and Acquisitions/Exit Planning - QuickRead Featured

    Dissenting Shareholder Appraisal Rights and Shareholder Oppression Claims

    Similarities and Differences in Securities Valuation Over the past three decades, the number of both dissenting shareholder appraisal rights claims and shareholder oppression claims have increased significantly. This increase has created a demand for forensic-related business and security valuation services. Valuation analysts are not legal counsel, of course. However, valuation analysts who practice in this area should be generally familiar with both the economic and the legal differences between dissenting shareholder appraisal rights issues and shareholder oppression issues. While taking specific legal instruction from legal counsel, valuation analysts should have a general familiarity with the professional guidance provided by the…

  • Litigation Consulting - QuickRead Featured - QuickRead Top Story

    Lost Profits: The Reasonable Certainty Standards and the Modern New Business Rule

    While the vast majority of jurisdictions have moved away from the new business rule and adopted the modern new business rule, by which new/unestablished businesses can recover damages, such adoption does not diminish the requirements under the reasonable certainty standard. Given the lack of historical financial performance data and under the lens of the reasonable certainty standard, estimates of lost profits damages to new/unestablished businesses are subject to a higher level of scrutiny. This article focuses on new/unestablished businesses and the importance of post-incident business-specific data/facts to isolate the effects of the disputed event, and to establish a measure of…

  • Litigation Consulting - QuickRead Featured

    One of AIG’s Largest Shareholders Put the Terms of AIG’s Bailout on Trial

    Moral Victory: Plaintiff Wins the Battle (Causation) But Loses the War (Damages) AIG collapsed in the wake of Lehman’s bankruptcy filing and required a government bailout in order to avoid the same fate as Lehman. The plaintiff (AIG’s shareholders) contended that they were harmed by the relatively harsh bailout terms that were imposed on AIG but no other bailout recipients. The defendant (U.S. government) countered that AIG’s bailout terms were: (1) legal, and (2) benefitted the plaintiff because a bailout under relatively harsh terms was better than no bailout at all. This article explains why the court held that: (a)…

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    The Valuation Analyst’s Role

    In Economic Substance Analyses Valuation analysts and other financial advisers are often called on to perform economic substance analyses in federal income tax challenges. In these cases, the Internal Revenue Service challenges a tax deduction or loss related to a taxpayer transaction by applying the so-called economic substance doctrine. This doctrine allows the Service to disallow a taxpayer transaction if the taxpayer (or the taxpayer’s expert witness) cannot prove that: 1) the taxpayer expected to earn a profit (absent any income tax considerations) on the transaction, and 2) the taxpayer had a reasonable business purpose for entering into the transaction.…

  • Litigation Consulting - QuickRead Featured - QuickRead Top Story

    Mediation 101

    Understanding the Magic Mediation is an exceedingly simple and yet extremely powerful dispute resolution process. Principles, process, and prerequisites coalesce to produce the magic of mediation. Those understanding the essential three “P’s” of mediation benefit by becoming better negotiators, thus producing more satisfying results and enjoying higher settlement rates.

  • Litigation Consulting - QuickRead Featured

    Lost Profits, Business Cycles, and the Reasonable Certainty Standard

    Part 1: Find Industry and Location-Specific Data Courts standards require that damages analysis results be within “reasonable certainty”, and objective rather than speculative. And while the terms “reasonable certainty” and “speculative” are more terms of art than science, given these standards, it is of vital importance to analyze all relevant factors to the extent permitted by the best data available. And it is the responsibility of the damages expert to present an analysis that is both reasonably certain and objective by engaging in reasonable effort to request and/or research the best data available. The expert that is unable to isolate…