Corporate Valuation & Advisory Services
Appraisals by asset class
Business Need
Foreign Interest Expense
Internal Revenue Code (IRC) Section 861 allows corporations to make an election to allocate interest expense between their foreign and domestic operations based on Fair Market Value of its property, plant and equipment rather than on a tax basis. Given the accelerated depreciation policies in the U.S., corporate tax basis in the U.S. is considerably less than that of an identical asset overseas. This election is an available option for corporate tax minimization and, once implemented, requires corporations to stay with the Fair Market Value election. This can lower the worldwide effective tax rate. As required, AccuVal can help companies minimize foreign interest expense by annually evaluating all tangible assets worldwide once the election is made to determine Fair Market Value.
- Trigger Events
- Related Services
- Get Started
- You are an international company with operations in the U.S. and abroad and there are indications that the value of your internationally based property, plant and equipment has declined and/or your domestic values have increased substantially
- An IRC Section 861 election has been made
- Save money on your property taxes
- Attack over-assessments by filing an appeal when the assessed value of real property is higher than your property’s Fair Market Value
- Establish proper insurance coverage
View AccuVal’s Appraisal Expertise by Asset Class:
- Copy of your most recently filed 10K
- Complete listing of all your holdings and the current tax basis
- Call 800 852-9252 or
- Submit an online request
