Developments Relating to Intangibles in Transfer Pricing
In 2013, new cost sharing regulations became effective amid controversy surrounding the application of methods used in high profile court cases.
Valuation Critical for C Corp to S Corp Conversion
Why does an entity choose to convert from a C corporation to an S corporation?
Issues Pertaining to Accounting for Income Taxes
Valuation allowances are one of the areas frequently challenged by auditors.
FATCA: What You Need to Know
FATCA has created a major compliance burden for all involved parties: withholding agents, FFIs, NFFEs, and the IRS.
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.