Valuations can be a critical component of effective tax planning. Whether you are a public or private company, a multi-national organization or an emerging business, Grant Thornton’s Valuation Services professionals can serve as integral members of your tax compliance and planning strategies team. A comprehensive business valuation across a company’s entire capital structure, including common shares, must be robust and complete to meet regulatory guidelines. We can provide the oversight, coordination and skills to assist with:
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Election to recognize gain – IRC 83(b)
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Discharge of indebtedness income – IRC 108
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Worthless securities deduction – IRC 165(g)
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Partially worthless securities – IRC 166(a)
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Charitable contributions and gifts – IRC 170
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Golden parachute payments – IRC 280(g)
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Distribution of property – IRC 301
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Redemption through use of related corporation – IRC 304
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Taxability of corporation on distribution – IRC 311
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Basis of property received in liquidation – IRC 334
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Distributions received in liquidation – IRC 336
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Deemed asset purchase – IRC 338
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Transfer to corporation controlled by transferor – IRC 351
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Distribution of stock and securities of a controlled corporation – IRC 355
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Foreign corporations – transfer of property – IRC 367
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Limitation on net operating loss carryforwards – IRC 382
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At risk requirement – IRC 465
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Allocation of income and deductions among taxpayers – IRC 482
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Definition of real estate investment trust – IRC 856
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Interest expense apportionment – IRC 864
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Allocation of interest US branches of foreign banks – IRC 882
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Puerto Rico and possession tax credit – IRC 936
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Exchange of property held for productive use of investment – IRC 1031
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Special allocation rules for certain asset acquisition – IRC 1060
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Passive foreign investment corporation – IRC 1287
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“C” corp to “S” corp conversion – IRC 1374
