A two-day introduction and update with live instruction on the U.S. transfer pricing rules under Sec. 482

Benefits of Attending

• Learn how the U.S. transfer pricing regime applies to related party sales and purchases of products by U.S. companies
  
• Find out how the IRS determines the amount of tax and penalties due on transactions with related parties, including conduit entities
  
• Obtain the latest information on when U.S. tax adjustments may be required for intercompany service or financing arrangements
  
• Determine if your company/client benefits under the new Proposed Cost-Sharing regs. or should retain its current licensing arrangements
  
• Receive an update on the latest IRS tools for resolving pricing controversies, including APAs, mediation, early referral and accelerated issue resolution
  
• Increase your knowledge of how transfer pricing influences your company’s financial statement results after Sarbanes-Oxley
  
• Discover how to prepare a Transfer Pricing Study under the Sec. 482 regulations

Educational Course Credit — Up to 16 CPE / CLE Credits Available

Substitutions/Cancellations

Cancellations received more than 72 business hours prior to the meeting will be issued a credit. A $350 fee will apply to cancellations received within 72 business hours of the event. No credit card or cash refunds will be issued at any time. For more information regarding administrative policies, such as complaints and refunds, please contact us at 1-914-328-5656, or e-mail info@citeusa.org. Credits will not be issued for "no shows"

A limited block of rooms at a reduced rate has been set aside for attendees of our conferences. Please contact the hotel and mention that you are attending the conference listed under the Council for International Tax Education (CITE) in order to receive the discounted rate. Sleeping rooms are available on a very limited basis. We cannot guarantee rates or availability. Your sleeping room is not included in your registration fee.Meetings held at conference centers with local hotel recommendations do NOT have rooms blocked

Meetings held at conference centers with local hotel recommendations do NOT have rooms blocked

Times/Topics Subject to Change

Day One

8:00 am Registration and Continental Breakfast

9:00 am Overview of the U.S. Transfer Pricing Regime under Sec. 482

• How U.S. companies today are expected to comply with the Sec. 482 arm’s-length standard – income shifting v. clear reflection of income
   

• When Sec. 482 applies in the international context – definition of related party and application to pass-through entities
   

• Finding a database for comparable profits methods
   

• Documenting intercompany sales for Forms 5471 and 5472

10:15 am Refreshment Break

10:30 am Establishing an Arm’s-Length Price for Sales and Leases

• How to compute the Best Method for intercompany sales of products and inventory – use of an inter-quartile range
   

• What companies or products must apply the CUP, resale price or cost plus method – analysis of recent cases
   

• When the comparable profits method (CPM) applies on sales to or purchases from a related party
   

• Special issues in dealing with the First Sale rule – interrelationship with Sec. 1059A

12:15 pm LUNCHEON

1:30 pm Arranging for Intercompany Transfers of Intangible Property

• How intangible property is defined – interrelationship with Secs. 197 and 367(d) – who is the legal owner?
   

• Finding a comparable uncontrolled transaction (CUT) – using the CPM or profit split method
   

• Understanding the latest IRS cost sharing regulations – what costs are included and who are qualified participants
   

• Recent case law and IRS rulings – treatment of stock options in cost sharing arrangements

3:15 pm Refreshment Break

3:30 pm Managing the Corporate Transfer Pricing Function

• Identifying products/products line that require a Transfer Pricing Study
   

• Monitoring corporate data for documenting intercompany transactions – determining the Best Method
   

• Managing IRS audits - how penalties apply if you don’t play by the IRS rules – interrelationship with the foreign tax credit rules
   

• Use of an economist

5:00 pm Meeting Ends for the Day

Day Two

8:00 am Continental Breakfast

8:45 am Preparing a Transfer Pricing Study

• Documenting related party transactions to mitigate penalty assessments under Sec. 6662(e) and develop a global compliance solution
   

• Accessing economic data for comparable companies and conducting a statistical analysis
   

• Using software for preparing a transfer pricing study and leveraging in-house resources
   

• Completing an economical Transfer Pricing Study to meet reporting requirements in multiple taxing jurisdictions

10:00 am Refreshment Break

10:15 am Understanding the New IRS Rules for Intercompany Services

• When a related party is required to charge for services – drafting an intercompany services agreement
   

• Treatment of stewardship or ancillary services – when you must impute a profit or mark-up on service costs
   

• What direct or indirect service costs can be charged to a related party – contingent consideration
   

• Determining the charge for services rendered as an integral part of the taxpayer’s business

11:30 am The Role of Transfer Pricing in Managing Your Global Effective Tax Rate

• Current financial statement audit environment - impact of transfer pricing audits
   

• Model Audit Program and issues to consider
   

• What should multinationals do? – complying with the new FIN #48 standards
   

• What should financial statement auditors do?

12:30 pm LUNCHEON

1:30 pm Resolving IRS Transfer Pricing Controversies

• Verifying or measuring estimated transfer pricing charges – budget v. actual – making compensating adjustments
   

• Who handles the audit - things the IRS economist will ask for on audit – dealing with the International Examiner (IE)
   

• Latest strategies for exam-level settlements: fast track mediation, early referral and accelerated issue resolution (AIR) procedures
   

• Reconciling book and taxable income – computing operating income and expenses

2:45 pm Refreshment Break

3:00 pm Transfer Pricing Audit Administration and Procedure

• Adjustments required to close the audit with the IRS – filing an APA Annual Report
   

• Obtaining relief using collateral and correlative adjustments or offsetting accounting entries
   

• Filing for an APA with the IRS – effect on open audits
   

• Protecting the statute of limitations in the U.S. and overseas – invoking competent authority relief

4:30 pm Meeting Ends

CITE Conference Registration - Page 1

There are 3 ways to register for a CITE Conference:

1. Complete this form and fax Page 2 to 914-328-5757
2. Call us directly at 914-328-5656
3. Complete the online registration process

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