Major Tax Issues Impacting Private Equity Firms
Various forms of executive compensation have become popular, resulting in much scrutiny, particularly in how these forms of compensation are taxed.
Revised Transfer Pricing Guidelines Focus on Valuation of IP
Comparability is the key factor in determining the arm’s length range.
Tax and Financial Reporting Differences in an Allocation of Purchase Price
One of the key differences in valuations for tax vs. financial reporting lies in the definition of value.
Valuation Considerations Relating to Section 382 Limitations
As a result of tax reform (TCJA), there are now three components to the Section 382 limitation amount.
Understanding Transfer Pricing Rules in China and Vietnam
In practice, there are certain requirements to be aware of when dealing with transfer pricing situations in China and Vietnam.
Valuation Plays Key Role in Section 338 Elections
Sec. 338 elections take two forms: the Sec. 338 (g) election, used for foreign acquisitions, and the Sec. 338(h)(10) election, used in domestic cases.
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.
Tax Considerations During Troubled Economic Times
For companies who have not filed for bankruptcy, the insolvency exception is critical.
Valuation Plays Key Role in FIN 48 Compliance
Many companies have already adopted FIN 48 and have turned their attention to the annual disclosure requirements.
Cost Sharing Agreements an Effective Tax Planning Tool
The impact of the investor model is that it essentially guarantees a return to the intangibles developer for its efforts.