• Dispositions of Tangible Property
• Expiring NOLs – accelerate income and defer deductions to utilize NOLs
• Maximize tax benefit of the transaction costs incurred in connection with merger, acquisition, restructuring, spin off, etc.
• Optimize methods of accounting for various items of income and expense in initial return
• Pass-through entity, service provider and small business: change the overall method from accrual to cash
• Production Activities Deduction
• Producer or reseller of inventory: minimize impact of Section 263A
• Quasi permanent deferral of income taxes and increase cash flow, by deferring items of income and accelerating items of deductions
• U.S. manufacturing, software development, construction, engineering services, architectural, and agricultural operations – maximize the Section 199
• Volume rebates, allowances, price protection, product returns, etc. –acceleration of deductions

• Benefits/reimbursements provided to employees outside the U.S. or non-U.S. nationals working in the U.S.
• Compensation/pensions/other income paid globally
• Employees moved into/out of U.S. on a short or long-term basis
• Global operations
• Gross Up calculations for relocated employees
• Tax calculations of globally mobile employees

• Exporter of goods with U.S. source content (IC-DISC)
• Needs to fund non-U.S. operations for expansion, acquisitions, etc.
• Non-U.S. tax compliance, tax attribute tracking, and U.S. international disclosures
• Plans to repatriate non-U.S. earnings
• Plans to restructure overseas supply chain
• Seeks to reduce income taxes in non-U.S. jurisdictions
• Unused Foreign Tax Credits
• S. multinational entity, U.S. or non-U.S. owned
• Offshore Voluntary Disclosure Program

• Analysis of R&D expenses
• Making a product, manufacturing process, or software better, faster, cheaper, or greener
• Paying for engineering, software-development, or physical or biological services
• R&D credits against AMT Tax
• R&D credits against payroll taxes for start-ups

• Accounting for acquisitions
• Automating tax provision preparation process
• Material weakness or significant deficiency in accounting for income tax
• Too few people, or significant turnover among tax department staff

(Cost Segregation, Tangible Property Regs, Green Energy)

• Acquired or Constructed Real Property for Cost Segregation
• Energy efficient building components for 179D
• IRS audit, FIN48 reserve, or Uncertain Tax Position related to fixed assets or depreciation
• Need/desire to increase cash flow by accelerating depreciation deductions

Clients who have or will have:

• Amended federal returns
• Assessed or paid IRS penalties
• Federal carrybacks
• M&A and restructuring activity
• Refund claims (federal)
• Offers in compromise
• Overpaid employment taxes

• Exemption analysis (environmental, foreign trade zones, etc.)
• Overpayment of real or personal property taxes
• Property Tax Certifications
• Property Tax returns

• Affiliated member of a group
• Filing in multiple states
• Nexus Study
• Sells services or products that are not tangible personal property
• Significant sales for resale, to exempt parties, to manufacturers, or other tax exempt sales
• State exam or state assessments
• State net operating losses
• Unclaimed Property

• Audit by IRS or other taxing authority, regarding cross-border transactions
• Concern about requirement of transfer pricing documentation
• Federal Form 5471 and/or Form 5472
• Interested in reducing costs in supply chain and/or repatriation of profits
• Multinational related entities with cross border transactions

• Agreed Upon Procedures
• Cyber Security
• Data Hosting
• Data Mining
• Disaster Recovery
• Due Diligence
• Expense Reduction Studies
• Financing Assistance
• Fractional CFO Services
• Managed Service
• Mergers & Acquisitions
• Quality of Earnings
• Strategic Planning
• SOC Certifications
• Succession Planning
• Value Enhancement Services (VOP)
• Buy-Sell Agreement Planning

• Benefit plans requiring plan audits and Form 5500 tax return preparation
• Equity-based compensation, e.g., stock options, restricted stock or profits interests in an LLC
• Executive compensation plans/split-dollar plans
• Form 5500 preparation
• Investment funds that require audits, e.g., “common collective trust”
• Mergers, acquisitions, spin-offs, etc.
• Public company auditor looking for audit support, e.g., preparing financial statements, disclosures, adjustments
• Retirement plan including cash balance and cross tested plans
• 100+ employees

• Involvement in energy or renewable energy business
• Plans for expansion, consolidation or divestiture
• Plans for major capital investments
• Plans for job increases, downsizing, and/or relocation
• State negotiated incentives
• Targeted employee groups (i.e. Veterans, disadvantaged families, etc.)

• Closely-held business and succession
• Concierge Premier Lifestyle
• Early stage or venture-capital-backed company
• Estate and gift planning
• Exit Planning/Succession
• Founder/CEO is high net worth individual with complex tax issues
• Owners planning to sell business to generate liquidity
• Wealth Advisory
• Will Review and Planning

• Bankruptcy Support
• Buy-Sell Agreements
• Estate Tax Planning
• Gifting
• Marital Dissolutions
• Mergers & Acquisitions
• Shareholder Buyout and Buy In
• Value Enhancement

• Fair market value paid to seller, and shorter time frame to closing
• Potential for no income tax paid by the business in the future
• Privately held business looking for liquidity without forfeiting control
• Reward and retain management team and key employees
• Smooth transaction without disruption by M&A process
• Tax-advantaged buyout of founder/owners

• Assistance with Discovery
• Construction Delays
• Contract Damages
• Fraud Detection
• Insurance Claims
• Litigation Support
• Lost Profits
• Matrimonial Dissolutions and Prenuptial Agreements
• Shareholder/Partner Disputes
• White Collar Crimes

• Due diligence and/or structuring services associated with planned or prior acquisitions or merger
• Evaluation of asset vs. stock for buyer or seller
• Excess cash that needs to be deployed or distributed
• Looking to raise significant capital e.g., organic growth, liquidity
• Newly formed entity
• Planned or prior acquisitions
• Principals seeking partial or complete exit
• Transactional modeling services
• 338(h)10
• 351/721 transaction, asset acquisition
• 754 Step-up