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Tax Reporting > Transfer Pricing and Purchase Allocation
Our staff has extensive experience in conducting 482 analyses and in the underlying evaluations of intangible assets and intellectual property. We have a long history of handling IRS disputes over intellectual property valuations and 482 pricing at the exam, appeal, and trial levels, and thoroughly understand the IRS and judicial mindset. Our success stems from the technical depth of our staff and academic network, and our extensive experience in valuing intellectual properties and assessing transfer payments. We have valued a wide variety of assets, including:
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Companies acquire and divest assets to complete their business models, achieve strategic goals, and increase cash flow. But they also care a lot about taxable income. When a company transfers intellectual property to a foreign subsidiary, the parent company must receive a fair payment or royalty for the use of that technology. If the payment or royalty is too low, the company will underpay its U.S. taxes and incur the wrath of the IRS. Section 482 of the Internal Revenue Code establishes guidelines for companies to determine proper royalty rates and payments.