Serving Clients Nationwide
- PPA, Transfer Pricing, Economic Analysis
- PPA, Transfer Pricing, Economic Analysis- PPA, Transfer Pricing, Economic Analysis- PPA, Transfer Pricing, Economic Analysis- PPA, Transfer Pricing, Economic Analysis
Valuation, Allocation, Transfer Pricing, and Economic Analysis
Alpha Consulting US provides independent valuation, purchase price allocation, transfer-pricing, and economic-analysis services for capital-intensive assets and cross-border enterprises.
Our practice brings together:
- Data center and infrastructure valuation
- Purchase price allocation and asset classification
- Cost segregation and Qualified Production Property analysis
- Transfer-pricing documentation and benchmarking
- Commercial reasonableness and economic analysis
- Independent decision support
We serve investors, owners, operators, developers, lenders, attorneys, accountants, tax advisers, and other professional advisers nationwide.
Data Center & Infrastructure Valuation
Infrastructure assets frequently derive value from more than land and physical improvements. Power availability, specialized equipment, operating capabilities, contractual interests, development status, and execution risk may materially affect value.
Our analyses address:
- Data centers and powered development sites
- Energy and power infrastructure
- Utilities and power generation
- Industrial and logistics assets
- Telecommunications infrastructure
- Enterprise and special-purpose entity interests
- Specialized operating assets
The objective is to determine economic value while considering asset composition, operating utility, market position, project risk, and the realistic buyer universe.
Purchase Price Allocation & Capital Allocation
Complex acquisitions may contain several distinct components of value:
- Real property
- Machinery and equipment
- Other business personal property
- Identifiable intangible assets
- Enterprise value and goodwill
Purchase price allocation determines how acquisition-date fair value is assigned among acquired assets and liabilities for financial reporting under ASC 805 or applicable IFRS standards.
Our analyses may address:
- Purchase price allocation
- Real and personal property
- Machinery and equipment
- Identifiable intangible assets
- Functional and economic obsolescence
- Asset classification
- Cost segregation and Qualified Production Property
Cost Segregation & QPP
Cost segregation allocates construction or acquisition cost basis among applicable federal tax-depreciation classes. Qualified Production Property analysis addresses whether qualifying portions of certain domestic production facilities may be eligible for special depreciation treatment under IRC §168(n).
These analyses may help owners:
- Identify and classify eligible assets
- Separate land, building, personal property, and land improvements
- Evaluate short-life depreciation classifications
- Analyze Qualified Production Property where applicable
- Improve capital-recovery timing
- Support tax planning and documentation
Cost segregation allocates tax basis. Purchase price allocation assigns fair value.
The two disciplines serve different purposes but both require careful asset identification, cost reconciliation, and classification.
Tax elections and return positions remain subject to determination by the taxpayer and its CPA or tax adviser.
Transfer Pricing
Alpha provides transfer-pricing documentation and economic analysis for U.S. companies engaged in cross-border transactions with foreign parents, subsidiaries, and other related parties.
Our selective middle-market practice addresses:
- Transfer-pricing documentation
- Benchmarking and comparable-company analysis
- Controlled purchases and sales
- Management, engineering, and technical services
- Intercompany financing and guarantees
- Technology, intellectual property, and royalties
- Startup losses and market adjustments
- Prospective market-entry pricing policies
- Asian inbound investment and U.S. subsidiaries
Transfer pricing is fundamentally an economic discipline. The analysis considers the functions performed, assets employed, risks assumed, contractual relationships, market conditions, and financial results of the controlled parties.
A benchmarking study may establish an arm’s-length range or prospective pricing policy. Complete transfer-pricing documentation ordinarily requires additional functional, financial, transactional, and method-selection analysis.
Economic Analysis
Capital-intensive assets and cross-border enterprises may require analysis beyond a conventional appraisal. Their economic performance can depend on capital recovery, technological change, operating risk, market conditions, transfer-pricing policies, financing assumptions, and the ability to sustain productive use.
Our economic analyses address:
- Commercial reasonableness
- Capital-recovery requirements
- Technological obsolescence
- Functional and economic obsolescence
- Investment feasibility
- Infrastructure investment risk
- Financing and exit assumptions
- Independent decision support
We evaluate investments under real-world operating and market conditions.
The relevant question is often not simply:
“What is the value?”
It is also:
“Can the investment recover its capital, remain economically productive, and ultimately be financed or transferred under realistic market conditions?”
Independent Judgment Where It Matters Most
Alpha Consulting US operates at the intersection of:
Valuation × Allocation × Transfer Pricing × Economic Analysis
Independent analysis is particularly important when:
- Capital deployment is substantial
- Infrastructure assets are complex
- Power and operating capacity affect value
- Asset classification is material
- Cross-border controlled transactions affect financial results
- Technological change creates obsolescence risk
- Financing and exit assumptions require validation
- Conventional appraisal metrics are insufficient
David Hahn, Valuation Economist
Managing Director
Data Center & Infrastructure Valuation | Purchase Price Allocation | Transfer Pricing | Economic Analysis
Phone: 213-251-2400
Email: david@alphaconsultingus.com