A two-day course with live group instruction on common transfer pricing methodologies and concepts for accountants, attorneys and other tax practitioners.

Benefits of Attending

• Learn how to comply with the U.S. transfer pricing rules
• Learn how to prepare effective documentation
• Discover how to prepare a Transfer Pricing Study under the Sec. 482 regulations
• Learn about the feasibility of doing it in-house
• Find out how the IRS determines the amount of tax and penalties due on transactions with related parties, including conduit entities
• Learn about the current transfer pricing developments
• Receive an update on the latest IRS tools for resolving transfer pricing controversies, including APAs and Competent Authorities proceedings

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

8:30 am Overview of Transfer Pricing

Module #1 Plenary Session

9:00 am Analyzing the Intercompany Transfers of Tangible Property

• Available methodologies - interrelationship with customs values
• How to determine when transactional methods  are more reliable than profit based methods
• Examples of common intercompany transactions involving sales of tangible property – types of distributors

10:30 am Refreshment Break

Module #2 Plenary Session

10:45 am Analyzing the Intercompany Transfers of Intangible Property

• How intangible property is defined – interrelationship with Secs. 197 and 367(d) – who is the legal owner?
• Available methodologies
• Finding a comparable uncontrolled transaction (CUT) – using the CPM or profit split method
• Examples of analyzing common intercompany transactions involving intangible property

12:15 pm LUNCHEON

Module #3 Plenary Session

1:30 pm Analyzing Intercompany Services

• Available methodologies
• Do you qualify for the Services Cost Method
• When  you must impute a profit or mark-up on service costs
• Treatment of stewardship or other non-chargeable functions
• Examples of analyzing common intercompany services transactions

3:00 pm Refreshment Break

Module #4 Plenary Sessions (Part A & Part B) - Part A

3:15 pm Analyzing Intercompany Financial Transactions

• How to benchmark intercompany loans, guarantees, cash pooling arrangements and other intercompany financial transactions
• Examples of analyzing common intercompany financial transactions

Module #4 Plenary Sessions (Part A & Part B) - Part A - Part B

4:00 pm Cost Sharing Regulations

• Understanding the latest IRS cost sharing regulations – what costs are included and who are qualified participants
• Examples of analyzing intercompany cost sharing arrangements

4:45 pm Q & A - Summary and Review of Day One

5:00 pm Meeting Ends for the Day

Day Two

8:00 am Continental Breakfast

Workshop Session #1

8:30 am Preparing a Transfer Pricing Study

• Documenting related party Transactions to mitigate penalty assessments under Sec.6662 (e)
• Accessing economic data for comparable companies and conducting a statistical analysis
• Preparing contemporaneous documentation - Example
• Global documentation strategies

10:00 am Refreshment Break

Workshop Session #2

10:15 am Practical Approaches to Most Common Transfer Pricing Documentations

• Satisfying the rules for contemporaneous transfer pricing documentation
• Transfer pricing penalties
• Practical solutions to common transfer pricing issues - Examples
1.          Financial analysis       
2.          Forms 5471/5472/8865
3.          Risk-function analysis
4.          Determining the tested party
5.          Economic analysis

12:15 pm LUNCHEON

Module #5 Plenary Session

1:15 pm Understanding the OECD Transfer Pricing Guidelines

• Source of OECD Directives – who applies OECD standards?
• How to determine when OECD transactional methods are more reliable than OECD profit based methods
• Comparison with U.S. rules for transfers of tangible and intangible property – documentation standards outside the United States

2:30 pm Refreshment Break

Module #5 Plenary Session

2:45 pm Handling IRS Transfer Pricing Controversies

• Verifying or measuring estimated transfer pricing charges – budget v. actual – making compensating adjustments
• Who handles the audit? What will the IRS ask for on audit
• Dealing with Appeals and IRS counsel
• The APA alternative: Negotiating a successful APA
• Deciding whether Competent Authority is the right path

4:15 pm Q & A - Summary and Review

Bloomberg BNA | CITE Conference Registration - Page 1

There are 3 ways to register for a Bloomberg BNA | 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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