Braxton provides services in international or global structuring. There are tax consequences to your operational business decisions—whether you extract an underperforming business unit for disposition, acquire a company, or rationalize your current organizational structure.

Transfer pricing

In today’s global economy, deleveraging governments are seeking mechanisms to stem the tide of tax-base movement and in some cases are looking to generate revenues in their unstable domestic productions. As a result, it’s critical that multinational companies and companies with international operations, not being multinationals in nature, have transfer policies and procedures in place that attempt to price intercompany transactions in accordance with arm’s-length principles. The failure to consider transfer pricing rules and regulations carries with it substantial business and tax penalties.

Braxton has continued to expand its range of services in transfer pricing. We understand that one size doesn’t fit all, so we work within your company’s risk profile and exposure tolerance.

Disposition planning and loss realization

The economy changes, markets change, and business units change. Time and again, management undertakes the process of measuring the internal rate of return for an investment and the consequences of discontinuing those operations. All too frequently those measurements are done without the benefit of understanding the tax consequences. Understanding the character of gains and losses, the jurisdictions where they will be reported, and the impact on your financial statements can serve to clarify decisions.

In loss realization, there’s a fundamental difference between the way company management and tax professionals perceive business operations. Management looks to the consolidated operations of the business, whereas tax professionals look to the jurisdictional components of the business. Taxes are measured on a jurisdictional basis. Companies, as they integrate and restructure, may find themselves with trapped losses (whether fully valued or not) in one entity that cannot be offset against operating income in other jurisdictions. Braxton can help integrate these tax components to monetize the losses (or other tax attributes) that are deferred.