The transfer pricing benefit must be assessed and negated for each tax year, not on a hindsight basis over the total loan period. The determination of arm’s length profits, and any “excessive” interest deductions, had to occur year by year. This was fundamental to how the tran...
a key issue in the case, is unconstitutional. These range from Apple, which could be due $37.3 billion, to Google, which could receive tax breaks worth $10 billion.
The ATO’s experts were Robert Weiss and Gregory Johnson of Global Capital Advisors. Mr. Weiss asserted a strong version of implicit support that would result in an estimate of the credit rating equal to A. This was the position of the tax authority’s expert witnesses inAlberta v. Enmax E...
The market value of Atmos Energy is measured differently than its book value, which is the value of Atmos that is recorded on the company's balance sheet. Investors also form their own opinion of Atmos Energy's value that differs from its market value or its book value, called intrinsic ...