Foreign Direct Investment: Tax and Valuation Considerations
In the case of a U.S. acquisition of a foreign target, it was oftentimes beneficial to make a Section 338(g) election.
Transfer Pricing Rules in Canada: An Overview
Canada, like the U.S., imposes a thorough set of documentation requirements, and imposes penalties for failure to comply.
Valuation Considerations for Acquisition Structures
A key tax consideration is whether the acquirer will be entitled to a stepped up tax basis in the assets and thus entitled to future tax deductions.
Deferral of Cancellation of Debt (COD) Income Could Result in Substantial Tax Saving
Determining the degree of insolvency is a key step since this will dictate the amount of COD income which may be excluded.
Valuation Integral to Sec. 409A Requirements
The valuation of a development-stage company’s common stock is best estimated using the methods in the Practice Aid.