Abstract: A method of achieving off-balance sheet treatment via bifurcated sale and leases. Initially one identifies a real property consisting of land and improvements. Then one determines a value of the improvements and a rental value of the land. Thereafter one estimates a remaining economic useful life of the improvement, a maximum cost associated with the transaction and a maximum cost comprising professional fees, financing fees and closing costs. The entity is capitalized so that substantive non-consolidation of the entity and the company results from the transaction. Title to the improvements is transferred from the company to the entity, and the value of the improvements is transferred from the entity to the company, wherein the company provides no financing of the transferred amount.

Abstract: Disclosed is a method for increasing earnings per share for a taxpayer without revealing attorney-client or work product privileged information. In one embodiment, the method includes the steps of: determining a tax reserve amount in connection with a transfer pricing transaction in a tax period; reserving a tax reserve for financial statement purposes, the amount of the tax reserve being equal to the determined tax reserve amount; obtaining an insurance product from an insurer, the insurance product insuring a portion of the tax reserve amount and being issued by the insurer without the insurer reviewing attorney-client or work product privileged information; and reversing to income, for financial statement purposes, the tax reserve amount that is insured by the insurance product. In another embodiment, the invention provides a method for determining whether an application to insure a given amount in connection with a transfer pricing transaction for a given taxation period constitutes an insurable risk.