Tax accounting in IRS dispute

In Ambac’s bankruptcy proceeding, Brattle evaluated and opined on the proper tax accounting for Ambac in its tax dispute with the IRS regarding the taxpayer’s $700 million tax refund during the global financial crisis. The dispute involved the appropriate taxation of credit derivatives, an unsettled area in tax policies and regulation. Brattle’s expert explained the difference between financial accounting, statutory accounting, and tax accounting for the financial losses. The case settled in our client’s favor.