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Representative Tax Valuation Services
Ad Valorem Property Taxes
In spite of the emergence and swift increase in other forms of taxation, property taxes remain a major source of income providing almost l7 percent of state and local governments' earnings. Most property taxes are "ad valorem," meaning the tax is based on the value of the property. A property tax review can lead to meaningful savings.
To further this goal, HSSK provides valuation related services ranging from preliminary studies that assess whether potential for tax reduction exists to detailed valuations and expert testimony in support of formal appeals. HSSK Business Valuation Group has extensive experience in every major industry. For any corporation that decides to negotiate, appeal or litigate its tax assessment, HSSK's experience can be an invaluable asset.
Estate and Gift Tax
HSSK provides professionally developed opinions of Fair Market Value for use in complying with Federal estate and gift tax laws. We are guided by the applicable IRS code sections, rulings and court decisions (including Revenue Ruling 59-60) dealing with the appraisal of all types of closely held business equities. Additionally, as in all of our appraisals, HSSK follows the business valuation standards set forth by the American Society of Appraisers and the Uniform Standards of Professional Appraisal Practice (USPAP). The result is an independent and defendable opinion of value likely to withstand challenges. The entire area of estate and gift tax valuations is a constantly shifting field making it all the more critical to have a qualified appraiser be part of a client's estate planning team. The professionals at HSSK should be part of this team.
Family Limited Partnerships
Over the past decade Family Limited Partnerships and other types of family controlled holding companies have become one of the most popular estate planning tools. Aside form the business purposes of such entities, such as centralized management and protection of assets from creditor claims, they also may offer some estate planning advantages through valuation discounts. The valuation of Limited Partnership and similar interests typically requires the application of discounts from pro rata value for both Lack of Marketability and Control. These discounts are derived from actual market evidence but must also be supported by the facts and circumstances unique to every partnership. The resulting Fair Market Value can be very useful in transferring ownership from one generation to the next with the least tax impact. The appraisers at HSSK work with tax attorneys, CPAs and other estate planning professionals in their efforts to help clients achieve their family's goals. This experience provides a unique perspective and results in an effective and defendable appraisal if challenged.
Intercompany Transfer Pricing, including Intellectual Property
As businesses expand globally, international transfers of products and services between affiliates have grown rapidly. Every United States firm, with foreign operations - regardless of size - is required to implement and document their transfer pricing in compliance with IRC §482. In addition, the Organization for Economic Cooperation and Development's Committee on Fiscal Affairs has set guidelines that are very similar to the United States' code. However, regional differences in transfer pricing policy are important and include formatting, record keeping, and methodology preferences, coupled with the need for a solid understanding of the general environment. This generates an escalating call for multinational firms to focus on their transfer pricing policies and to seek innovative solutions to them. The corporate taxpayer may best support his position by having the economic analysis and transfer pricing documentation prepared by an independent expert. HSSK specializes in the type of independent, economic analysis required to conduct and substantiate a transfer pricing study.
Interest Expense Attribution IRC
Under IRC regulations, members of an affiliated group are required to allocate interest expense against foreign-source income as if they are one taxpayer rather than separate entities. This must be achieved by multiplying the group’s total interest expenditures by the ratio of its foreign assets to its total assets. Under the regulations, taxpayers may elect either a tax book value basis or a fair market value basis on which to perform this allocation. Relying on the fair market value method may provide the corporate taxpayer significant savings.
HSSK’s skilled professionals possess the requisite understanding of the regulations as well as the valuation expertise to provide a fair market valuation of the affiliated group as a whole as well as its underlying domestic and foreign assets. Our studies are designed to fully satisfy the IRC regulations governing this election and withstand the scrutiny of the Internal Revenue Service. Our extensive experience with the Service ensures that our methods and findings are supportable.