Annual report pursuant to Section 13 and 15(d)

Related Party Transactions

v2.4.1.9
Related Party Transactions
12 Months Ended
Dec. 31, 2014
Related Party Transactions  
Related Party Transactions

(13) Related Party Transactions

During the years ended December 31, 2014, 2013 and 2012, certain of TruePosition’s costs and expenses were charged to TruePosition by Liberty. The amounts due to (from) Liberty and the activities for the years ended December 31, 2014 and 2013 are summarized as follows (amounts in thousands):

 

 

 

 

 

 

 

 

    

2014

    

2013

 

Payable (receivable) at beginning of year

 

$

(5,953)

 

2,876 

 

Costs and expenses charged by Liberty

 

 

3,913 

 

2,808 

 

Amounts (receivable) due under the tax-sharing arrangement

 

 

(4,094)

 

4,493 

 

Transfer of related party receivable to (from) note receivable

 

 

5,306 

 

 —

 

Payments to Liberty

 

 

(6,399)

 

(16,130)

 

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

 

 

7,227 

 

 —

 

(Receivable) payable at end of year

 

$

 —

 

(5,953)

 

 

Prior to the completion of the Broadband Spin-Off, TruePosition also had an intercompany note arrangement with Liberty under which funds were advanced to Liberty and remitted back to TruePosition as needed. During September 2014, Liberty remitted back to TruePosition all principal and accrued interest related to this note and the arrangement was extinguished. As of December 31, 2013, the outstanding note receivable from Liberty plus accrued interest was $19.1 million. The note bore interest at the three-month LIBOR plus 2%.  

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, $13.6 million in 2013 and $10.7 million in 2012 under these tax sharing arrangements. As of December 31, 2013, TruePosition had a $6.4 million income tax receivable due from Liberty. 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.