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Examining Forecasts and Potential Profitability in an IRS Appeals Matter

Brattle consulted for attorneys representing Veolia Environnement SA (France) in a decade-long tax dispute over a $4.5 billion worthless stock deduction. Our experts analyzed a series of contracts for their profit potential and demonstrated the insolvency of the business. We prepared significant new analyses rebutting IRS arguments with market evidence to explain why a turnaround was impossible. Ultimately, the IRS conceded the case in full.

Practices
Tax Controversy & Transfer Pricing
Tax Controversy & Transfer Pricing

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Examining Forecasts and Potential Profitability in an IRS Appeals Matter