Tax Considerations During Troubled Economic Times

For companies who have not filed for bankruptcy, the insolvency exception is critical.

Valuation Integral to Sec. 409A Requirements

The valuation of a development-stage company’s common stock is best estimated using the methods in the Practice Aid.

Deferral of Cancellation of Debt (COD) Income Could Result in Substantial Tax Saving

Determining the degree of insolvency is a key step since this will dictate the amount of COD income which may be excluded.

Valuation Considerations for Acquisition Structures

A key tax consideration is whether the acquirer will be entitled to a stepped up tax basis in the assets and thus entitled to future tax deductions.

Transfer Pricing Rules in Canada: An Overview

Canada, like the U.S., imposes a thorough set of documentation requirements, and imposes penalties for failure to comply.

Foreign Direct Investment: Tax and Valuation Considerations

In the case of a U.S. acquisition of a foreign target, it was oftentimes beneficial to make a Section 338(g) election.

Current Practice Issues Pertaining to Sec. 409A

In the original Practice Aid, there was no mention of the back-solve approach. Since then the technique has come into widespread use.

How Do You Put a Price Tag on the Panama Canal?

​How Do You Put a Price Tag on the Panama Canal?