Valuation allowances are one of the areas frequently challenged by auditors.
FATCA has created a major compliance burden for all involved parties: withholding agents, FFIs, NFFEs, and the IRS.
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.
By employing a cost segregation study, a significant portion of a property may be reclassified to a shorter life category.
When a company embarks on an international restructuring, it is extremely important to consider the impact of Section 367.