Transfer Pricing (Section 482) – US Company (US) with a German subsidiary. US transferred some software to Germany and required two things to comply with IRC Section 482: (1) value of the IP; and (2) appropriate royalty rate to charge US for usage of software.
Equity Participation – as part of an incentive plan for key employees, healthcare client required valuation of several entities. These companies were reorganized into a new firm. Also, involved the installation of a Profits Interest Plan that will grant equity based upon future financial results.
Allocation of Purchase Price – included two purchases of security system firms. Valuation satisfied book accounting requirements under ACS 805, and included customer list, non-compete agreements, and complicated earnouts.