(Part IV of IV) This is the final article of the four-part series that sets forth best practices for estimating the company-specific risk premium. This discussion of the series summarizes best practices about the analyst’s conduct of the functional analysis as one component in developing the CSRP estimate. [su_pullquote align=”right”]Resources: Best Practices for Estimating the Company-Specific Risk Premium (Part I of IV) Best Practices for Estimating the Company-Specific Risk Premium (Part II of IV) Best Practices for Estimating the Company-Specific Risk Premium (Part III of IV) [/su_pullquote] Introduction Valuation analysts (analysts) often apply income approach business valuation methods to value…
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Forensic engagements that involve determining lost profits or other economic damages often require a “time series” of economic and market data. When the lost profits or other economic damages engagement involves comparing international companies, multi-country economic data, and international market data, the challenges in locating meaningful data become especially difficult. In this article, the authors share how a time series analysis was used in an engagement, resulting from a breach of a franchise in a European Union (EU) country. To perform the time series analysis, the authors needed to gather multi-country economic data to determine the alleged lost profits and/or…
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In Related-Party Cost Sharing Arrangements (Part II of II) This two-part paper demonstrates how the discount rate associated with the investment in intangibles developed under a cost sharing arrangement can be calculated using an analytical framework that explicitly considers variability of outcomes in profitability of the intangibles to be developed. Such framework is the probability-weighted scenario analysis. The method of calculating discount rates using the scenario analysis can be applied to compute the PCT payment under both the “income method” and the “residual profit split method” described in the U.S. transfer pricing regulations. The same method also allows to calculate…
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In Related-Party Cost Sharing Arrangements (Part I of II) This two-part paper demonstrates how the discount rate associated with the investment in intangibles developed under a cost sharing arrangement can be calculated using an analytical framework that explicitly considers variability of outcomes in profitability of the intangibles to be developed. Such framework is the probability-weighted scenario analysis. The method of calculating discount rates using the scenario analysis can be applied to compute the PCT payment under both the “income method” and the “residual profit split method” described in the U.S. transfer pricing regulations. The same method also allows to calculate…
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Writing on behalf of BIAC, Will Morris said that many MNEs that have centralized intra-group services centers expend significant sums supporting audits for intra-group payments. He said the goal for this project should be to create clear, simplified, rules and safe harbors, where possible. Existing guidance should be clarified, not expanded, he said. To read the full article in MNE Tax, click: OECD Publishes 77 Comments on Transfer Pricing Guidelines for Intra-Group Services, Dispute Resolution.
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Mergers and acquisitions (M&A) have continued growing since 2008’s financial crisis. Through the first three months of 2016, the value of worldwide M&A totaled nearly $750 billion. Cross-border M&A activity totaled $308 billion—accounting for a quarterly record-high 41% share of global M&A value. As in previous years, M&A in industries with hefty intangible assets—such as pharmaceuticals and technology, media and telecom—dominated deal making.[1]
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The Case of Trademarks and Brands Since the adoption of fair value accounting governed by SFAS 141 (in 2001) and IFRS 3 (in 2004), hundreds of thousands of different intangible assets have been valued, audited, and reported in financial statements of public companies all over the world. After fifteen years of fair value accounting, the debate about the accuracy of such values and their relevance for readers is no less controversial than at its beginning. This is a pity because, in its essence, fair value data is an excellent resource for corporate finance professionals to understand more about the value…
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Despite all the talk about new changes underway now that Republicans will assume control of Congress and governorships in 31 states, much of the current tax issues will look the same in 2015 as they did in 2014, according to Forbes. Below is a snapshot of the top nine tax stories to watch in 2015: Business Taxes. Will 2015 be the year of business tax reform? Probably not, according to Forbes, as the Affordable Care Act and battles over spending will continue to swallow up lawmakers’ focus and time this coming year. Dynamic Scoring. GOP leaders have introduced rule changes…