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    Temporary Regs. Under Sec. 482 Coordinate Transfer-Pricing Rules with Other Code

    Regulations Clarify Arm’s-Length Standard for Transfer-Pricing Rules The temporary regulations provide that the arm’s-length standard of Sec. 482 applies to all controlled transactions without regard to the form or character of the transactions, and they are particularly concerned with tax-favored transfers of assets outside the U.S.  Jay L. Camillo, M.A. (international relations), Atlanta, and Kenneth P. Christman Jr., J.D., Washington, explain. To read the full article in The Tax Adviser, click: Temporary Regs. Under Sec. 482 Coordinate Transfer-Pricing Rules with Other Code.

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    Structuring the Intangible Asset Analysis Assignment

    The standard 10 stages to use in an intangible asset engagement In this second installment, Robert F. Reilly completes his review of the 10 typical stages of any intangible asset analysis engagement. For purposes of this article, an intangible asset analysis may include a valuation, damages analysis, transfer price study, or other economic analysis. The business appraiser will typically consider these stages, or elements, before, during, and after performing any quantitative or qualitative analyses.

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    Structuring the Intangible Asset Analysis Assignment

    The standard 10 stages In this first half of his two-part series, Robert F. Reilly summarizes six of the ten typical stages of any intangible asset analysis assignment. For purposes of this article, an intangible asset analysis may include a valuation, damages analysis, transfer price study, or other economic analysis. The business appraiser will typically consider these stages, or elements, before, during, and after performing any quantitative or qualitative analyses.