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.
When valuation is important for tax purposes, breakdown by legal entity is key since each has its own tax identity and related tax consequences.
In the case of a U.S. acquisition of a foreign target, it was oftentimes beneficial to make a Section 338(g) election.