Our extensive experience with tax matters makes Caliber Advisors unique among tax valuation advisors. Our staff has been involved in dozens of tax controversy matters, ranging from estate and gift tax matters to transfer pricing and income tax matters. Our experience with testimony, courtroom considerations and the resolution process gives us invaluable perspectives on valuation and economic issues.
We have extensive experience in Section 482 analyses and a long history in handling IRS disputes involving transfer pricing matters. Having worked at the exam, appeal and trial levels on these issues, we understand the rubric of the IRS and the U.S. courts.
Our success stems from the technical depth of our staff and academic network. We also draw on our extensive experience in structuring joint venture and partnership arrangements in university and institutional technology transfers.
Our clients include Fortune 500 companies and we have worked across a wide number of industries on transfer pricing matters, including the Pharmaceuticals, Computers and Electronics, Industrial Services, Software industries.
Other Corporate Tax Matters
There are a number of corporate transactions and elections that can trigger tax liabilities. We have worked in a wide variety of these matters in both a reporting context and in a litigation context.
Practice highlights in common corporate matters include valuation of:
- C–to–S corporation conversions (IRC 1374)
- goodwill and asset allocations between related entities
- NOL limitations (IRC 382)
- IP donations and charitable contributions of stock (IRC 170)
- asset sales in non-profits (IRC 503c)
- contingent interest income (expense)
Practice highlights in compensation related matters include fair market value analysis of:
- arm’s length executive compensation
- equity compensation in option grants (IRC 409a)
- golden parachutes and non-competition agreements (IRC 280g)
Gift and Estate
Measuring and supporting the value of private (and illiquid public) interests for tax purposes requires understanding critical “red flag” issues to comply with the IRS and the U.S. Tax Court. We have provided opinions on some of the most complex estate tax issues and have extensive experience defending our analyses at exam, appeals and trial.
Practice highlights include valuation of:
- partial interests in property and family limited partnership
- related party notes
- contingent payment obligations (guarantees, warranties)
- equity and debt interests in closely held companies
- restricted equity in publicly traded companies
Caliber’s tax litigation services are spearheaded by valuation analysts and expert witnesses with decades of experience working on federal income and estate tax matters. We have deep experience analyzing valuation and economic issues and establishing fair market value and arm’s length pricing measures.
We have substantial experience addressing tax disputes at the examination, appeals and litigation levels. We know how the system works at each level, and can provide valuable insight into the likely development of a case through the dispute process. We have substantial testimony experience before Tax court and District court, and settlement experience in fast track, appeals and pre-trial settlement conferences.
Our staff has presented to IRS Appeals and testified in US Tax Court on matters including:
- Transfer Pricing:
- buy – in payments
- arm’s length payments and royalty payments
- stock option compensation
- Subpart F recognition
- Discounts for lack of control
- Blockage discounts
- Partnership interest valuation
- Private company valuation