Alan Alford Ph.D., CFA
Client concerns I can address
How will COVID-19 change my transfer pricing?
What costs can I allocate to my worldwide subsidiaries?
Should I refinance my cross-border loans or increase the leverage of some subsidiaries?
How do I integrate acquisitions into my tax structures?
How do I defend my transfer pricing transactions to auditors?
How do I value my intangibles and set transfer prices?
1. Planning for intercompany transactions
A. Meshing transactions with business policy
B. Intercompany financing and analysis
C. Support for offshore businesses
2. Documenting results from related-party transactions
3. Audit defense
A. Tax audits
B. Financial statement audits
4. Advance Pricing Agreements
5. Related-party credit guarantees
6. Integrating acquisitions and business restructurings
A. Valuing individual subsidiaries and businesses
B. Valuing intangibles for integration
C. Integrating transfer pricing policies—acquired companies with acquiring companies
D. Pricing technology licenses
7. Treasury operations
Major clients served
1. FInancial Services
A. Commercial Banking
B. Investment Banking
C. Internet Banking
D. Consumer lending
E. Banking services and funding
B. Information services
C. Semiconductors and technology
Alan Alford, Ph.D., CFA
Analyzing complex transactions to optimize your tax strategies
20+ years of providing transfer pricing, valuation, and financial advice worldwide
- Emphasizing the economics underlying the transaction and the business
- Working with the business, tax, and counsel to find the right solutions
- Consulting and in-house experience
Expert analysis of all classes of transfer pricing issues
- Supply chain issues and interruptions
- Debt, equity, and derivatives transactions
- Treasury operations and funding
- Hard-to-value intangibles
- Entity valuations
- Business restructurings, reorganizations, and integrations
Support for your tax strategy at all stages
- Preparing for transactions
- Documenting the arm’s-length nature of the policies
- Advocating positions in controversy procedures
Cost allocations sound simple, but become a major issue with tax authorities. I can help identify allocable costs and document why those costs should be borne by specific entities. Your documentation needs to show how those entities benefit from those expenses and how the provider incurred those costs.
Interest rates are falling. That could open up opportunities. What type of debt should I issue? What are my rates? What tenors? What currencies? How does this affect my treasury and cash pooling operations? You need to evaluate the alternatives and to find the structures that match your tax planning goals.
Your company may have just acquired a company with intellectual property held in the wrong location. You need to merge the acquired subsidiaries with your structure on a country-by-country basis. You need to reconcile the acquired company’s policies with your policies. You need to plan for new transactions or to change existing ones. You need to adapt your documentation to the new transaction structures of the integrated operations.
Successful audits depend on explaining your business to auditors, both the simple and the complex. You need cogent descriptions of how your internal business operates, where risks are borne, and how the individual components come together.
Simply put, the value of an intangible relates to the cash that the intangibles generate. Your transfer pricing policies determine what that cash will be. Your valuation necessarily will be a two-step process. First, set the transfer pricing, then set the intangible value. I can work with your business colleagues to understand how they use the intangibles and its contribution to the overall business. From there, I can help find the right value or license rate to assign to the use of the intangible.