Coca-Cola Tax Court Loss Reminds Companies to Watch IP Valuation - Bloomberg Tax

John Warner, shareholder in the firm's Tax section, is quoted in the Bloomberg Tax article, "Coca-Cola Tax Court Loss Reminds Companies to Watch IP Valuation."

“The problem is that such intangibles are so valuable because they are unique, and therefore there are no real comparables upon which to base a direct valuation of them,” said John Warner, a shareholder at Buchanan Ingersoll & Rooney PC in Washington.

“The valuation is indirect—measuring the residual income that the related party user of the intangibles should earn after paying such a royalty—in the case of Coca-Cola, through use of a CPM analysis of the ‘supply points’ that the court felt was straightforward because the those entities did not have any of their own valuable intangibles,” he added.