The fair market value election under Sec. 1.861-9T(g) can result in a more favorable interest expense allocation if, for example, there are U.S. assets with low tax bases but high fair market values.
Our valuation analyses establish the stepped-up inside basis of the assets to provide the starting point for the U.S. tax earnings and profits calculation.
Our gift and estate tax-related services include business enterprise valuations, capital stock valuations, tangible-asset valuations, and intangible-asset valuations.
Our professionals provide valuation services for such special projects as thin capitalization, check-the-box elections, and worthless stock deductions.
Situations where valuations can result in tax accounting differences include asset impairment, stock acquisitions, goodwill impairment, and derivatives.
Our services for transfer pricing include preparation of documentation for penalty protection, economic analysis for advanced pricing agreements (APA), and tax controversy support.
