White Paper 2018-04-03T15:39:31+00:00

Transfer Pricing & Business Valuation

THOUGHT LEADERSHIP

We are in the areas of intangible asset valuation, transfer pricing, and general valuation theory. Our and publications have been recognized by corporate clients, lawyers, and tax authorities as offering real advances. Our valuation models are transparently available to our clients, allowing us to work jointly with them on many of their most important valuation and transfer pricing matters.

Intangibles Planning under the Tax Cuts and Jobs Act

Welcome to the New World. The Tax Cuts and Jobs Act (“Act”) just made holding intangible property (“IP”) in the United States a lot more attractive, and holding IP outside the United States a lot less so. Doing so, it provides important benefits for U.S. domestic manufacturers that own IP in the United States, particularly those that export, and that did not heretofore own and develop IP through affiliates in low-tax jurisdictions.

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Strategic Dispute Resolution in a Post-BEPS World

The OECD/G20 BEPS initiative has been accompanied by increased audit activity around the globe, with tax authorities focusing on intercompany structures and transactions which, while often passing muster in the past, are now suspect. The EU State Aid decisions raise their own interesting questions, in that having a transaction ‘‘blessed’’ by a local tax authority no longer appears to offer complete protection from further inquiry and adjustment.

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EP White Paper & Transfer Pricing Articles | Amazon Transfer Pricing Case

Economic Issues Arising from the Tax Court Decision in the Amazon Transfer Pricing Case

Earlier this year, the U.S. Tax Court issued its decision in Amazon.com, Inc. v. Commissioner. The case involved various issues, with the larges dollar issue arising because of the “buy-in” payment that Amazon’s Luxembourg affiliate mate to Amazon US when the two entities entered into a cost sharing agreement in 2005. As will be discussed, the economic experts retained by the taxpayer and the IRS reached very different conclusions as to the value of the buy-in payment.

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409A valuation process - IMG

Tax Cuts and Jobs Act

This article focuses on the recently enacted Tax Cuts and Jobs Act and describes the major provisions impacting transfer pricing. The Act will result in significant changes to the U.S. taxation of cross-border transactions and foreign operations of U.S. multinational enterprises.

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