Results

A representative sampling of some of the great results achieved for our clients:

  • Integrated Oil & Gas Company DPAD Analyses

    Performed comprehensive reviews for major integrated O&G companies. Captured eight-figure tax benefits, and identified additional go-forward opportunities, involving DPGR reclassification, expense sourcing, and prior period costs.

  • Oil Refining & Trading DPAD Analysis and IRS Exam

    Identified and captured seven-figure refund claims for major oil refiner and trader. Reclassified DPGR, enhanced section 861 analysis, and sustained prior period cost treatment. Provided comprehensive IRS Exam support through successful resolution.

  • Integrated Energy Company DPAD Project

    Performed time-sensitive DPAD analysis of acquired company returns. Identified eight-figure refund claims.

  • Consumer Goods Company DPAD Analysis and IRS Exam

    Performed multi-year DPAD analysis and captured eight-figure benefits, primarily by performing more accurate “substantial in nature” analysis and developing a more accurate cost of goods sold methodology.

  • Manufacturer Refund Claims, Prior Period Costs, and Appeals Settlement

    Performed comprehensive DPAD refund analysis. Captured seven-figure benefit at IRS Exam and additional seven-figure settlement at IRS Appeals. Results achieved by identifying prior period costs and more appropriate application of section 861 principles.

  • DISC Implementation and Optimization

    Assisted countless exporters in IC-DISC formation and DISC commission calculation and optimization.

  • Section 861 Analysis with DPAD and FTC Coordination

    Performed comprehensive DPAD and FTC analysis. Identified aggregate eight-figure cost of goods sold, prior period cost, and section 861 opportunities. Evaluated consistency rule in context of prior, current and projected future-year tax results.