Large publicly traded companies are required to report the fair market value of business units or operations, intangible assets, or securities for federal, state, and local tax purposes, as well as to allocate income across the many international jurisdictions they operate in. Tax-related fair market value issues we’re retained for include:
- Valuations of intellectual properties or intangible assets for property tax reporting purposes.
- Valuations of intellectual properties or other intangibles for Sec 482 transfer pricing purposes.
- Valuations of non-compete agreements for Sec 280 purposes.
- Valuations of overseas subsidiaries.
- Allocations of the fair market value of securities issued, for the purposes of determining the original issue discount (OID) of debt instruments.
- Reorganizations, mergers, and acquisitions.