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Detailed
Information:
Arthur Consulting Group, inc. is an international consulting firm specializing
in economic and financial analysis, valuation, and tax consulting. Our
financial analysis practice provides analysis, documentation, and
expert testimony for applications such as:
Applications:
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Purchase Price
Allocations and step-up in basis for federal tax and accounting purposes,
as well as international withholding tax.
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IRC §482
Intercompany Transfer Pricing.
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Damages losses,
casualty losses and business interruption.
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Acquisition and
divestiture pricing.
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Determination
of capital gains.
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Estate valuation
for tax purposes.
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Royalty rate and
license fee valuation.
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Substantiation
of royalties for state tax purposes, when tradenames are owned out-of-state.
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IRC §861(e)
Interest Expense Attribution.
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Valuation for
customs declaration and other customs duty purposes.
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Fairness opinions,
solvency opinions, and due diligence.
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Quantification
of economic and technological obsolescence for property valuation
and property tax purposes.
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Quantification
and separation of intangible values from real property values for
property valuation and property tax purposes.
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Valuation of closely
held corporations for owner buy-out or other reasons.
Recent and Significant
Engagements
Below is a small number
of representative valuation projects of Arthur Consulting Group. More
complete lists and recommendations are available, by industry, region,
and application.
- Global proprietary
technology for one of the world's largest makers of brand name clothing,
for purchase price allocation.
- Worldwide assets
of a major integrated petroleum firm, for purposes of IRC §861(e) Interest
Expense Attribution.
- 1,500 patents for
a leading maker of consumer electronics, in its acquisition of a major
electronics firm.
- Casualty losses
from mislaunch of a satellite missile, including modeling of scenarios
which suggested commissioning of recovery mission.
- All underlying
assets of a leading media company including the television network it
owned, when acquired by a major conglomerate. At the time, it was the
largest non-energy acquisition in history.
- Intercompany transfer
pricing for chemicals division of a major integrated oil company. Proprietary
software of a top data storage device company and a leading semiconductor
equipment manufacturer, both for customs duty minimization purposes.
- Valuation and defense
of royalty rates for a major retailer, challenged in the State of New
York. Global underlying assets of a Fortune 50 manufacturer, in a challenge
of the taxpayer's interest expense attribution.
- Quantification
of economic and technological obsolescence of a food processing plant,
resulting in $80 million reduction for ad valorem tax purposes.
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