A two-day transfer pricing update with live group 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 U.S. MNCs and how to defend your company’s results with the IRS
• Discover the affect of transfer pricing in preparing financial statements and in recognizing FIN 48 liabilities
• Learn the latest strategies facing MNCs 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 avoid IRS audit
• Let our experienced faculty analyze for you how the latest IRS regulations affect existing and proposed 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 key economic transfer pricing principles in defending results at MNCs

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

Day One

8:00 am Registration and Continental Breakfast

9:00 am Managing the Corporate Transfer Pricing Function

• How U.S. companies today are expected to comply with the Sec. 482 arm’s-length standard - determining the Best Method
• Monitoring corporate data for documenting intercompany transactions on Forms 5471 and 5472
• Managing year-end transfer pricing adjustments
• Developing a global compliance solution for related party transactions to mitigate penalty assessments

10:15 am Refreshment Break

10:30 am Analyzing the Intercompany Transfers of Tangible Property

• How to select and apply the Best Method Rule for intercompany transfers of tangible goods
• Advantages and limitations on the use of historic survey data – establishing an arm’s-length range
• Determining the tested party - conducting a strategic functional analysis
• Interrelationship with customs valuation and first sale rule
• How to determine when transactional methods (i.e., CUP, Resale Price, etc.) are more reliable than profit based methods (i.e., CPM)

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 Understanding the IRS Rules for Intercompany Services and Financial Products

• When  you must impute a profit or mark-up on service costs
• Available methodologies – use of cost-based charges
• Treatment of stewardship or other non-chargeable functions
• The business judgment rule
• How to benchmark intercompany loans, guarantees, cash pooling arrangements and other intercompany financial transactions

5:00 pm Meeting Ends for the Day

Day Two

8:00 am Continental Breakfast

8:45 am Global Documentation Strategies to Avoid 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

10:00 am Refreshment Break

10:15 am Interrelationships of IRS Audits with Financial Statement Preparation

• Disclosure of IRS audit results in financial statements
• Determining FIN 48 disclosure - determining the amount of Recognized Tax Positions
• Preparation of Schedule UTP for Uncertain Tax Positions – current status on implementation – planning issues
• Accruing interest and penalties on tax underpayments

11:15 am Economic Aspects of Transfer Pricing Principles

• How the IRS economist may challenge crucial assumptions in your company’s 2010 and 2011 transfer pricing or IP buy-in payments
• Focus on more creative economic analysis in the face of highly publicized decisions and settlements in the United States, Canada, Australia, etc.
• How tight credit conditions affect the selection of profit level indicators and benchmark companies – making adjustments to comparables
• The role of the economist in preparing a Transfer Pricing Study
  

12:15 pm LUNCHEON

1:15 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) – dealing with IRS counsel
• Tiering of issues- what is it?, how does it affect case resolution?, and how to resolve a tier issue
• Resolution strategies for exam-level settlements: fast track mediation, early referral and accelerated issue resolution (AIR) procedures
• Post examination resolution – Appeals and beyond

2:45 pm Refreshment Break

3:00 pm Alternative Dispute Resolution Strategies

• The APA alternative: Negotiating a Successful APA
• When or why to consider an APA
• Deciding whether Competent Authority is the right path
• The current CA environment

4:30 pm Meetng Ends

BNA | CITE Conference Registration - Page 1

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