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).
International Media Companies
Reduced transition tax, captured FTCs subject to valuation allowance, and increased final-year DPAD, resulting in eight-figure refunds.
Medical Device Company
Identified additional deemed paid credits, reduced aggregate foreign cash position, and additional DPAD, leading to multi-million dollar adjustment to RAR.
Technology Company
Advised on proper treatment of section 304 transaction to capture multi-million dollar refund.
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.