Independent Insight for Value Opinions
Compliance and Documentation
The proliferation of transfer pricing compliance and documentation requirements, combined with a dramatic increase in the volume and complexity of international intra-group trade and the heightened scrutiny of transfer pricing issues by tax authorities, makes transfer pricing documentation one of the top tax compliance priorities on the agendas of both tax authorities and businesses.
Advance Pricing Agreements
Advance Pricing Agreements (APAs) are generally bi- or multilateral; they also include agreements between the taxpayer and one or more foreign tax administrations under the authority of the mutual agreement procedure specified in income tax treaties. The taxpayer benefits from such agreements since it is assured that income associated with covered transactions is not subject to double taxation by the IRS and the relevant foreign tax authorities. It’s possible that a taxpayer may negotiate a unilateral APA involving only the taxpayer and the IRS.
Functional and Economic Analyses
The Functional Analysis provides the factual foundation for determining the extent and economic substance of the related party activities that are undertaken by a renderer on behalf of a recipient. This analysis is a method of finding and organizing facts about a business in terms of its functions, risks, and assets in order to identify how these characteristics are divided between the entities involved and transactions under review.
Cost Sharing Arrangements
In general, a Cost Sharing Arrangement (CSA) is an arrangement by which the participants agree to share the cost of developing one or more intangibles (referred to as “covered intangibles” or “cost shared intangibles”) that will be separately exploited by each of the participants.
In the United States, CSA is governed by Treas. Reg. §1.482-7. By participating in a CSA, each participant obtains a separate interest in such cost-shared intangible. Consequently, each participant may separately exploit the cost-shared intangible in a manner consistent with that interest without owing additional compensation to the other participants.
How We Do It
At Marshall & Stevens, we use market-based pricing techniques, benchmarking studies, and other accepted valuation methodologies to incorporate inter-company pricing policies supported by established valuation theory, regulations, and well-established economic principles.
The result is a sound valuation for transfer pricing solutions that meet our clients’ business objectives, as well as the arm’s length requirements imposed by national tax authorities. Our valuation reports are prepared in conformance with the Organization for Economic Cooperation and Development (OECD) and applicable Treasury Department Guidelines.
For more information, please contact one of the professionals below.
How Marshall & Stevens can help with Transfer Pricing
Our Transfer Pricing team collaborates with our internal multi-disciplinary professionals to provide the value analyses and fresh independent opinions to fiduciaries, financing sources and investors for public and private company transactions.
Financial Valuation
Lawyers, accountants, wealth managers and other trusted advisors refer their important clients to us for financial valuation and consulting services.
Fairness Opinions
A Fairness Opinion from a disinterested valuation firm provides decision makers with an independent analysis of the transaction, unbiased by commissions and other potential conflicts.
Intangible Asset Valuation
Intangible assets are assets that, while lacking physical form, have value and can, in many cases, add value to other assets, services and businesses. Some intangible assets can be integral to the value of an...
Frequently Asked Questions
The Marshall & Stevens Difference
Marshall & Stevens provides Fairness and Solvency Opinions, valuation analyses, investigative accounting, and expert witness services to assist public and private clients with their important transactions and litigation matters.
- 11 offices
- over 200 employees
- 26 Unique Professional Certifications
- 8 firms acquired since 2023
- 93 years (founded 1932)
- over 55 staff with tenure of 9+ years
Client Highlights
Here are a few client success stories from public and private companies we’ve worked with
Transfer Pricing Contacts at Marshall & Stevens
Background
Jonathan Adelson is a Managing Director, Business Development with Marshall & Stevens.
Mr. Adelson joined Marshall & Stevens in 2024. He leads business development efforts with public and private companies, private equity funds, and turnarounds to deliver independent financial opinions with respect to valuation, solvency, capital adequacy and fairness in connection with mergers, acquisitions, divestitures, leveraged buyouts, recapitalizations, financings and financial and tax reporting matters for businesses, equity and debt securities, loans, derivative instruments, structured products, intangible assets, fixed assets real estate and more.
Prior to Marshall & Stevens, Mr. Adelson was a Manager at KPMG and a Managing Director at Alvarez & Marsal. He has served in business development roles for Valuation Research Corporation, Adelson Strategies (a global business development and strategy firm), and Trio Media Ventures. He began his career in public policy.
Mr. Adelson volunteers with multiple organizations.
Professional Highlights
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Managing Director, Business Development, 2024-present - Valuation Research Corporation
Managing Director, 2017-2024 - Adelson Strategies
Managing Director, 2015-2017 - Trio Media Ventures
Founder, Head of Global Strategy & Business Development, 2015-2017 - Alvarez & Marsal
Managing Director, 2005-2015 - KPMG LLP
1998-2005
‣ Manager, 1999-2005
‣ Intern, Washington National Tax Practice, Summer 1998
- American Iron and Steel Institute
Law Clerk, Office of the General Counsel and VP of Public Policy, Summer 1995 - Liz Robbins Associates
Junior Associate, Washington Representatives, 1991-1994
- Bondville Fair (Bondville, VT)
Board of Directors, 2023-present - The M&A Advisor 2022 (New York, NY)
Advisory Board, 2022-2023 - The Stratton Foundation (Stratton, VT)
Volunteer, 2020-present - Stars of Hope (New York, NY)
Volunteer, 2019-present - Progressive Policy Institute (Washington, DC)
Board of Directors, 2016-present - Ithaca College Alumni Association (Ithaca, NY)
Board of Directors, 2002-2008
Background
Martin Hanan is a Managing Director with 40 years of business valuation, transaction and business economics consulting experience. He was the founder and President for ValueScope, and joined Marshall & Stevens in 2024, with their acquisition of ValueScope. He works primarily in transaction advisory and financial valuation.
Having created two industry-leading firms, Mr. Hanan has managed hundreds of engagements for other professional advisors, and government and corporate clients in a wide array of industries.
Mr. Hanan’s expertise includes the valuation of closely held business interests, financial derivatives, and intellectual property; governance issues including executive compensation; and financial and tax reporting issues including transfer pricing, transactional assistance and methods designed to accelerate corporate cash flow and value.
Mr. Hanan’s strengths include deep insight into econometrics, theory and methodology, business appraisal, and empirical analysis. He is highly analytical, quantitative and creative, and utilizes these skills in assignments ranging from value measurement to value harvesting to expert testimony.
Professional Highlights
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- Dallas Society of Financial Analysts
- Beta Gamma Sigma Alumni - Dallas Chapter
- Scale Marketing LLC, Director
- Director, Project Chimps (non-profit)
- Former Director, Einstein Noah Bagel Corp.
- Former Director, Luna Carpet, Inc.
- Former Director, Board of Trustees, Alliance for Higher Education / North Texas Regional Center for Innovation and Commercialization
- ValueScope, Inc.
Founder and President, 2001-present - Business Valuation Services, Inc.
Founder and President, 1987-2000 - H.D. Vest Business Valuation Services, Inc.
President, 1987 - Touche Ross & Co.
Senior Manager, Valuation Engineering and Appraisal Services, 1986-1987 - Arthur D. Little Valuation
Manager, 1983-1986 - Motorola Govt. Electronics Group
Design and Manufacturing Engineer, 1978-1982
Background
Scott Hakala is a Managing Director with more than four decades of experience working with finance, economics, statistics, and business valuation theory. He joined Marshall & Stevens in 2024, with the acquisition of ValueScope. He works primarily in litigation expert witness services and financial valuation. His expertise includes:
- Corporate Finance
- Restructuring and Cost of Capital
- Valuation of Securities and Business Interests (e.g., transactions, mergers, acquisitions, fairness opinions)
- Valuation of Intangible Assets (e.g., patents, trademarks)
- Analysis of Publicly Traded Securities (e.g., insider trading studies, trading analyses, event analyses, materiality, damages in securities litigation)
- Expert Testimony and Economic Loss Analyses (e.g., commercial litigation)
- Wage and Compensation Determination (e.g., reasonable compensation studies, lost personal income, wrongful termination)
- Transfer Pricing
- Derivative Securities (e.g., options pricing and valuation)
- Antitrust and Industry Structure, Strategic Pricing, Marketing, and Cost Allocation Analyses.
Professional Highlights
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- ValueScope, Inc.
Managing Director, 2014-present - CBIZ Valuation Group, LLC
1992-2014
‣ Managing Director, 2009-2014
‣ Director/Principal, 1995-2009
‣ Senior Consultant, 1992-1994 - Laser BioTherapy, Inc.
Consultant/Interim CEO, 1998 - Southern Methodist University, Dept. of Economics
Assistant Professor, 1988-1992 - University of Minnesota, Dept. of Economics
Lecturer, 1983-1988
- Southern Methodist University
Assistant Professor, Dept. of Economics, 1988-1992
‣ Macroeconomics, monetary/financial economics, financial institution regulation, and international financial management (graduate and undergraduate level) - University of Minnesota
Lecturer, Dept. of Economics, 1983-1988
‣ Macroeconomics and international financial management
Background
Steve Hastings is a Managing Director with experience in business financing, as well as the analysis of market dynamics in various industries. He joined Marshall & Stevens in 2024, with the acquisition of ValueScope. He works primarily in transaction advisory, litigation expert witness services, and financial valuation.
Mr. Hastings' expertise includes creating and analyzing financial derivatives; structuring management compensation plans; strategic business planning; due diligence and tax advisory services; negotiation assistance and investor communications. He has provided services to companies in numerous transactions involving business appraisals, sales, mergers and acquisitions; as well as having been a party to numerous complex financing transactions.
Mr. Hastings has provided expert testimony in trials and depositions related to financial matters.
He served six years as a Finance Commissioner of Texas. The Finance Commission provides overall policy and supervisory control for the Banking Department, the Savings and Loan Department, and the Office of Consumer Credit Commissioner.
Professional Highlights
.collapsible { background-color: #d9eafc; color: black; cursor: pointer; padding: 10px; width: 100%; border: none; text-align: left; outline: none; font-size: 16px; font-weight: bold; } .active, .collapsible:hover { background-color: #d9eafc; } .content1 { padding: 0 18px; display: visible; overflow: hidden; background-color: #fff; } var coll = document.getElementsByClassName("collapsible"); var i; for (i = 0; i < coll.length; i++) { coll[i].addEventListener("click", function() { this.classList.toggle("active"); var content = this.nextElementSibling; if (content.style.display === "block") { content.style.display = "none"; } else { content.style.display = "block"; } }); }- American Institute of Certified Public Accountants
- Texas Society of Certified Public Accountants
- American Society of Appraisers
- National Association of Certified Valuation Analysts
- AICPA Business Valuation & Forensic Litigation Support
- Financial Executive Institute
- ValueScope, Inc.
Managing Director, 2006-present - Value Capital, LLC
Principal, 2001-2006 - Finance Commission of Texas
Director, 1994-2000 (public service) - MedCare Financial Solutions, Inc.
President, 1994-2001 - H.D. Vest Financial Services
Executive Vice President and CFO, 1986-1994 - Arthur Andersen & Co.
Senior Manager, 1979-1986
Relevant Insights
MS Capital Investment Banking
Fairness Opinion Advisory
