Tax Reporting
Our tax court and appeals experience gives us invaluable perspectives on valuation and economic issues.
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.
Transfer Pricing
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
Corp. 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, and NOL limitations (IRC 382).
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.
Tax Controversy
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.