Historical Development - Who We Are

Declining trade barriers, along with marketing integration, have combined to bring the challenge of international operations to many companies.  Our team in the INTERNATIONAL SERVICES division has worked in more than 200 countries outside the US.  Our services apply to acquisitions, divestitures, restructures and other transactions with regulatory implications, including tax optimization across multiple tax systems.

•  Purchase price allocations

•  Transfer pricing analyses

•  Assistance with interest expense allocation and apportionment options

•  Check-the-box services

•  Fairness opinions and solvency opinions

•  Royalty rate studies

•  Business enterprise valuations for reorganizations

•  Post-acquisition integration services

•  IP valuations related to cost-sharing agreements

•  In-process R&D in business acquisitions

•  Valuations for estate and gift tax purposes

•  Lease valuations

•  Audit support

•  Litigation support and expert testimony

Sections 864(e) and 861, Allocation of Interest Expense
For purposes of computing allowable foreign tax credits, taxpayers follow IRC Sec. 864(e), implemented through Temp. Treas. Reg. Sec. 1.861-11T, which requires that interest expense deducted on the US tax return be allocated and apportioned to US and foreign source income. A taxpayer may elect to value its assets based on their fair market value, rather than tax book value. A fair market value approach has proven to be advantageous, resulting in millions in tax savings for some companies.  The regulations, however, are extremely detailed and complicated. To help tax executives with their decision-making process, ACG offers clients a cost-saving Phase I analysis, which models the effects of an actual Section 864(e) election.

Section 482, Transfer Pricing
Transfer pricing is an issue of prime importance for multinational corporations; however, the preparation of contemporaneous transfer pricing documentation is generally very costly. To assist our clients in significantly reducing their transfer pricing expenses and potential exposure, ACG developed a unique software program that allows a company’s internal experts access to the comparable company data and analytical tools needed to perform all or selected parts of a rigorous IRC Sec. 482 analysis.  A demo model of ACG’s 482LBox™ is available upon request.

"We operate domestically and in
more than 200 countries outside
the United States."

Central America
Eastern Europe
Europe Union
Middle East
North America
South America
The Caribbean             












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