IIC, Inc. has considerable experience in the analysis of a variety of tax issues including transfer pricing, asset (tangible and intangible) and privately held firm valuations, business behavior with regard to taxation, and impacts of taxation on firm strategy including pricing, organizational behavior, and product development. We have assisted clients in analyzing the appropriate methods for computing transfer prices, royalties, and valuation of intangibles under the IRS Section 482 regulations. We have also participated in the negotiation of Advanced Pricing Agreements. We have been engaged frequently in appraising the value of a particular asset or group of assets and developing the fair market value of an entire business entity. We also have extensive experience in evaluating the business purpose and economic substance relating to various transactions and contractual relationships, including lease-stripping transactions related to Section 351 of the Internal Revenue Service code. Such work frequently involves disputes about the appropriate methodology as well as assumptions and data inputs, and we are careful to provide not only a well-reasoned and defensible valuation, but also one that is understandable and easily explained. From time to time taxation authorities impose taxes that may be unconstitutional, unfair or illegal. Under such circumstances, the tax authority is often faced with perfecting a remedy that does not unjustly enrich the taxed entity. IIC, Inc. has worked successfully with numerous taxing authorities in crafting remedies that rely on fundamental principles of public finance economics to demonstrate the degree to which the affected entity may have absorbed the tax and the extent to which it passed on the burden of the tax to its consumers. |
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