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.

Tax Considerations During Troubled Economic Times

For companies who have not filed for bankruptcy, the insolvency exception is critical.

Valuation Plays Key Role in FIN 48 Compliance

Many companies have already adopted FIN 48 and have turned their attention to the annual disclosure requirements.

Cost Sharing Agreements an Effective Tax Planning Tool

The impact of the investor model is that it essentially guarantees a return to the intangibles developer for its efforts.

Purchase Price Allocations Support Section 338 Elections

In general, the impact of a Sec. 338 election is that a stock acquisition is treated as an asset acquisition.

Worthless Stock Deduction May Result in Tax Benefits

Obtaining a valuation from an independent valuation provider is essential to proving that the security has no liquidating value.

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.