A two-day transfer pricing update with live instruction for intermediate to advanced level tax practitioners responsible for documenting U.S. intercompany charges for cross-border activities

Benefits of Attending

• Understand how the current economy affects transfer pricing results at your company and how to defend your results with the IRS  
• Discover the affect of transfer pricing in preparing financial statements under SEC and IFRS standards and in recognizing FIN 48 liabilities  
• Learn the latest strategic selections facing multinationals today in establishing arms-length comparables for sales and service activities  
• Find out how your company can enhance shareholder value through migrating intangibles offshore and use of cost-sharing arrangements  
• Determine whether your company can utilize a Transfer Pricing Study to reduce or avoid penalties on transfer pricing adjustments  
• Learn what the IRS looks for on audit and the latest tools for resolving transfer pricing controversies  
• Find out the latest IRS solutions for resolving cross-border transfer pricing disputes, including arbitration and Advanced Pricing Agreements (APAs)  
• Featuring a special update on how states apply IRS transfer pricing principles in audits of multistate and multinational companies

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

Schedule
*Times/Topics Subject to Change*

Day One

8:00 am Registration and Continental Breakfast

8:45 am Economic Aspects of Transfer Pricing Principles

• How the IRS economist may challenge crucial assumptions in your company’s 2009and 2010 transfer pricing policies
   

• Focus on more creative economic analysis in the face of highly publicized decisions and settlements in the United States, Canada, Australia, etc.
   

• Advantages and limitations on the use of historic survey data – establishing an arm’s-length range
   

• How tight credit conditions affect the selection of profit level indicators and benchmark companies
  

10:30 am Refreshment Break

10:45 am Strategic Selection of a Transfer Pricing Method: CPM and Beyond

• Determining the tested party
   

• Conducting a strategic functional analysis
   

• Looking for CUPs in all the right places
   

• Resale Price and Cost Plus - when they can make the grade
   

• Using “Other” Methods – Don’t Panic – guidelines established in GlaxoSmithkline decisions in the United States and Canada

12:15 pm LUNCHEON

1:30 pm How to Maximize your Opportunities with Intangibles and Cost Sharing Agreements

• Identifying the owner of key manufacturing and marketing intangibles - distinguishing IP from IA
   

• Implications of licensing, transferring or funding intangibles and establishing an arm’s length range
   

• Selecting comparable uncontrolled transactions and use of the comparable profit margin (CPM) method
   

• The keys to effective Cost Sharing Agreements – treatment of stock options – valuing buy-in payments after Veritas decisio

3:00 pm Break for Refreshments

3:15 pm Managing the Corporate Transfer Pricing Function

• Country differences of comparability and re-aligning profits for market-based and technology intangibles
   

• What data is comparable for documenting intercompany transactions – determining the Best Method
   

• Role of transfer pricing in preparing financial statements
   

• Financial statement considerations - FIN 48 implementation steps
   

• Emerging trends in global transfer pricing disputes
  

5:00 pm Meeting Adjourns for the Day

Day Two

8:00 am Continental Breakfast

8:45 am State Tax Aspects of Transfer Pricing Controversies

• What the states look for on audit in combined reporting states
   

• Current state tax developments involving transfer pricing
   

• Using Sec. 482 to re-allocate profits between states
  

10:00 am Break for Refreshments

10:15 am Tax Planning for Intercompany Services

• How will the new regulations impact current intercompany service charges at my company?
   

• Understand how the new “Benefit” rule requires companies to expand the number of services charged to international affiliates
   

• Find out what services can be charged at cost
   

• Focusing on the cost base related to service calculations (including the requirement to include stock based compensation)
   

• How tax authorities in foreign jurisdictions treat US service charges
  

11:15 am Global Documentation Strategies for Avoiding Transfer Pricing Penalties

• Satisfying the rules for contemporaneous principal and background documentation using a Transfer Pricing Study
   

• Preparing a Transfer Pricing Study – verifying or modifying estimated targets for actual results
   

• How the 20% and 40% penalties are applied to the substantial or gross understatement of tax on an annual basis
   

• Understanding the exceptions to the Sec. 6662(e) penalty
  

12:30 pm LUNCHEON

1:15 pm Resolving IRS Transfer Pricing Controversies

• Things the IRS economist will ask for on audit – who handles the audit – meeting the International Examiner (IE)
   

• Things to think about before concluding the audit with the IE – litigation strategies - the use of aggregation analysis under Reg. Sec.1.482-1(f)(2)(i)
   

• Adjustments required to close the audit with the IRS – filing for relief with the Appeals Office – assessing hazards of litigation
   

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

3:00 pm Refreshment Break

3:15 pm Administrative Resolution of Cross-Border Pricing Disputes

• Handling multi-country transfer pricing controversies
   

• Use of arbitration to settle cross-border transfer pricing disputes in Canada
   

• How Advance Pricing Agreements (APAs) can be used to assist in resolving IRS audits – negotiating an APA
   

• When competent authority relief should be used for resolving cross-border pricing controversies
  

4:45 pm What You Should Take Home from the Meeting

5:00 pm Meeting Ends

CITE Conference Registration - Page 1

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1. Complete this form and fax Page 2 to 914-328-5757
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