Various forms of executive compensation have become popular, resulting in much scrutiny, particularly in how these forms of compensation are taxed.
Comparability is the key factor in determining the arm’s length range.
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 valuation of a development-stage company’s common stock is best estimated using the methods in the Practice Aid.
For companies who have not filed for bankruptcy, the insolvency exception is critical.
Many companies have already adopted FIN 48 and have turned their attention to the annual disclosure requirements.
The impact of the investor model is that it essentially guarantees a return to the intangibles developer for its efforts.