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.