A representative sampling of some of the great results achieved for our clients:
Chemical Company Transition Tax and FTC Benefits
Comprehensive review identified multi-million dollar transition tax opportunity and enhanced FTC by reducing overall foreign loss.
Management Company Transition Tax and Interest Expense Carryforwards
Identified opportunities to significantly reduce transition tax and reduce interest expense impacted by section 163(j).
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.