Annual report pursuant to Section 13 and 15(d)

Related Party Transactions

v3.3.1.900
Related Party Transactions
 12 Months Ended
Dec. 31, 2015
Related Party Transactions  
Related Party Transactions

(13) Related Party Transactions

During the year ended December 31, 2014 certain of TruePosition’s costs and expenses were charged to TruePosition by Liberty. The amounts due to (from) Liberty and the activities for the year ended December 31, 2014 are summarized as follows (amounts in thousands):

 

 

 

 

 

 

    

 

2014

 

Payable (receivable) at beginning of year

 

$
(5,953)

 

Costs and expenses charged by Liberty

 

 
3,913

 

Amounts (receivable) due under the tax-sharing arrangement

 

 
(4,094)

 

Transfer of related party receivable to (from) note receivable

 

 
5,306

 

Payments to Liberty

 

 
(6,399)

 

Amount receivable (due) under the tax-sharing arrangement transferred to Liberty Broadband

 

 
7,227

 

(Receivable) payable at end of year

 

$

 —

 

 

Prior to the completion of the Broadband Spin-Off, TruePosition was a party to certain tax sharing arrangements with Liberty (or its former affiliate). Under these tax-sharing arrangements, TruePosition had been obligated to make cash payments to Liberty (or its former affiliate) in each year TruePosition generated positive taxable income, determined as if TruePosition filed a separate tax return. The amount of such payment has been equal to the amount of TruePosition’s taxable income (as so determined) multiplied by the highest corporate tax rate in effect for the applicable tax jurisdiction. If on a separate return basis, TruePosition would have a net operating loss or net tax credit for a particular year, and such loss or credit could be utilized on the actual tax returns filed by Liberty (or its former affiliate), then TruePosition would be entitled to reduce current and future payments to Liberty (or its former affiliate) by the amount of such tax benefit. TruePosition made payments of $3.2 million in 2014 and $13.6 million in 2013 under these tax sharing arrangements. Prior to the completion of the Broadband Spin-Off, TruePosition’s income tax receivable from Liberty was transferred to Liberty Broadband and the tax sharing arrangement between Liberty and TruePosition was extinguished.