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.