We help clients comply with all State, IRS and U.S. Treasury rules and regulations when reporting for income tax purposes. The standard of fair market value pervades these rules and regulations whether it comes to transfer pricing, charitable contributions, and deductible intangible assets or goodwill.
Employee Stock Options / 409A Valuation
- Among other restrictions and guidelines, the key principle outlined in IRC Section 409A pertains to the issuance of deferred compensation, particularly employee stock options. Granting employee stock options or other share-based payment arrangements that are “in-the-money” (i.e., have an exercise price below the fair market value of the underlying asset) represents an immediate transfer of value and creates a taxable event. In addition, the valuation of a startup company or company issuing stock options often involves complex capital structures where company value needs to be allocated between different classes of ownership. BizValue has significant expertise preparing 409A valuations used to support the issuance of stock options (or other deferred compensation) in accordance with the guidelines issued by AICPA and with IRC Section 409A.
International or Internal Transfer Pricing
- Codified under Section 482 of the IRS regulations, the legal framework for transfer pricing in the U.S. is complex and relate to the following: What transfer pricing methods are accepted? Do the local tax authorities favor a given method? What dispute resolution mechanisms are available? Are APAs allowed and, if so, what are the rules? To what extent are international guidelines followed? How is the acceptability of comparables determined? What are the documentation requirements? How are non-compliance penalties calculated?
ESOP Valuation Services
- ESOPs are attractive vehicles for shareholder liquidity in certain circumstances due to their tax advantages. The basic ESOP structure involves the creation of a trust into which a company contributes new shares of its own stock or cash to buy existing shares. Company contributions to the trust are tax-deductible within certain limits, and C corporations may also deduct interest payments and reasonable dividends that are paid in cash. When employees of a privately-held ESOP company leave the company, they receive remuneration for the fair market value of their stock which the company must repurchase. Private companies must have an annual outside valuation to determine the price of their shares. At BizValue, we work with ESOP-owned companies and ESOP trustees, provide ESOP feasibility studies, fairness opinions, and annual ERISA-compliant ESOP valuations for planning and compliance purposes.
Closely Held Stock Valuations for Family Wealth Planning & Estate Tax Compliance
- We provide our clients with thorough valuation reports prepared in conformity with recognized valuation standards applicable to the valuation of closely held stock for estate tax purposes. Business and Intangible Asset Valuations in Connection with Electing Subchapter S Tax Status
- Businesses eager to demonstrate proper corporate governance depend on our professionals to establish the value of intangible assets for planning value-focused initiatives, as well as for commercial, tax and regulatory purposes.
Valuations for Charitable Donations
- Our professionals provide business valuation services and have the requisite expertise to meet the philanthropic needs of our clients. In today’s complex economic environment, obtaining a realistic valuation is essential to acquire a successful investment, meet compliance requirements, and achieve strategic goals. At BizValue, we provide our clients with understandable advice and solid guidance, helping them to accomplish their business objectives and personal goals.
