…many factors of a business must be considered when answering the question “what is the value of my closely held business.”
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.
Multinational companies face several compliance and planning issues.
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.
Canada, like the U.S., imposes a thorough set of documentation requirements, and imposes penalties for failure to comply.
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.