Brattle consulted for attorneys representing Veolia Environnement SA (France) in a tax dispute over a $4.5 billion worthless stock deduction that persisted over a decade. Brattle 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. Brattle worked closely with multiple law firms and advisors in Europe and the US to bring a new lens and new expert opinion to a long running dispute. Ultimately, the IRS conceded the case in full.