One of the key differences in valuations for tax vs. financial reporting lies in the definition of value.
As a result of tax reform (TCJA), there are now three components to the Section 382 limitation amount.
In practice, there are certain requirements to be aware of when dealing with transfer pricing situations in China and Vietnam.
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.
The impact of the investor model is that it essentially guarantees a return to the intangibles developer for its efforts.
By employing a cost segregation study, a significant portion of a property may be reclassified to a shorter life category.
In general, the impact of a Sec. 338 election is that a stock acquisition is treated as an asset acquisition.
When a company embarks on an international restructuring, it is extremely important to consider the impact of Section 367.
Obtaining a valuation from an independent valuation provider is essential to proving that the security has no liquidating value.
When valuation is important for tax purposes, breakdown by legal entity is key since each has its own tax identity and related tax consequences.