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Expense Allocation & Analysis (EA2) services

International Tax. Quantitative Consulting Services

Tax authorities worldwide are challenging multinational companies regarding two interrelated tax issues: allocation and apportionment of expenses to foreign source income under Internal Revenue Code §861 and the deductibility of items that should have been charged to foreign jurisdictions (charge-outs) under §482 – i.e., intercompany service transactions.

Documentation is the issue. Companies either have none to support their analysis, or what they have is outdated. Without current, accurate and supportable information, tax departments may struggle to produce reliable support and documentation.

Deloitte International Tax. Quantitative Consulting Services (IT.QCS) can help. The IT.QCS team brings a combination of tax technical experience, process knowledge and technology skills to the marketplace. We have developed a data collection and analysis process to help you deal with the interaction of §861 and §482. This process, along with our EA2 technology, can help you develop support for your tax positions – independent §861 studies or §482 charge-outs, or the interrelationships between the two.

Learn more about how IT.QCS can deliver the integrated, flexible and sustainable services you need to address your company’s exposure in today's complex international tax environment.

 

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