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.

Legislation Increases Benefits of Cost Segregation Studies

By employing a cost segregation study, a significant portion of a property may be reclassified to a shorter life category.

Valuation Provides Support for International Transactions

When a company embarks on an international restructuring, it is extremely important to consider the impact of Section 367.

Valuations Provide Critical Support for Asset Acquisitions

When valuation is important for tax purposes, breakdown by legal entity is key since each has its own tax identity and related tax consequences.

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.