New York, NY
Register Early and Save!
December 12 & 13, 2016
1221 Avenue of the Americas
New York, NY 10020
Hotel accommodations are at your own discretion. We suggest the following:
Renaissance New York Times Square Hotel
Two Times Square, 714 Seventh Avenue at W. 48th Street
New York, NY 10036
New York Hilton Midtown
1335 Ave of the Americas
New York, NY 10019
Join us for a two-day seminar that combines theory with hands-on practical applications.
This introductory seminar provides participants with (1) a working knowledge of key transfer pricing concepts and (2) an understanding of steps needed to document intercompany transactions.
During the first day, the seminar focuses on the principles and methodologies of transfer pricing. The next day, participants use examples and case studies to focus on practical applications of key transfer pricing concepts in common intercompany transactions.
This seminar covers the following:
• Primary transfer pricing methodologies and typical fact patterns
• Gathering and analyzing internal and external data
• Preparing functional analyses
• Creating/updating benchmarking data using internet resources
• Step-by-step preparation of a transfer pricing report
• Similarities and differences of U.S. and OECD transfer pricing reports
• Master, country and local file preparation
• Country-by-country reporting
• Handling transfer pricing controversies
What You Need to Know
8:00 am Registration and Continental Breakfast
8:30 am Welcome and Introduction
8:45 am Overview – Revisiting the Approach to Developing Defensible Transfer Prices
• Factual development before undertaking the best method analysis
• The best method rule revisited
o Transactional vs. profit based methods
o Why do tax authorities want to use profit based methods?
• Tangible Property
o Types of manufacturers
o Types of distributors
o Choice of transfer pricing methods
• Examples of Intercompany Services
o New issues, including imbedded intangibles
o Types of services
o Methods used in pricing services
• Intangible Property
o Types of intangible property (OECD vs. Sec. 482)
o Pricing transfers
o Approaches to pricing (OECD vs. Sec. 482)
10:30 am Coffee Break
10:45 am Intercompany Financial Transactions
• Debt versus equity and guarantee fees
• Pricing methods
o Guarantee fees
• Assessing ability to repay debt
o Current U.S. Rules
o Section 385
• Loan documentation
o OECD and U.S. perspectives including section 385
12:00 pm Luncheon
1: 30 pm U.S. Tax Controversies - Recent IRS challenges to Transfer Prices
• Buy / Cost Sharing Cases
• Intangibles / Tangibles
• Regulatory Challenges
o Chamber of Commerce (7874 challenge)
• Summons Enforcement Cases
2:40 pm Coffee Break
3:00 pm Foreign Transfer Pricing Challenges
• State aid concerns
• Local limited-risk distributers
• Holding companies
• Brexit response issues
4:00 pm Defending Transfer Pricing Controversies
• Strategies for Managing IRS Examinations
• Achieving favorable resolutions with IRS Appeals
• Alternative Paths—Competent Authority and APAs
• Strategies to settling cases in litigation
5:30 pm Networking Reception Hosted by Mayer Brown
8:00 am Continental Breakfast
8:30 am How to Perform BEPS Diagnostic
• Case study
• CBC issues
9:30 am Preparing a Transfer Pricing Analysis
• Financial analysis
• Risk-function analysis
• Economic analysis
10:45 am Coffee Break
11:00 am Preparing a Transfer Pricing Analysis - continued
• Case study – benchmarking analysis
12:00 pm Transfer Pricing Documentation (Best Practices)
• Legal documentation requirements under sec. 482 and BEPS
• Legal documentation issues related to various transactions
1:00 pm Seminar Concludes
SUBSTITUTIONS, CANCELLATIONS & COMPLAINTS
If you are unable to attend this event, you may: transfer your registration to another person from your company for the same event; or transfer your registration to a substitute event listed on our web site. In either instance, there will be no charge or penalty for substitution. To request a transfer, contact email@example.com with the new attendee or substitute event information more than 5 business days prior to the conference start date. On the first day of the event, absent attendees will be considered “no shows” and will not be eligible for a refund, transfer, or substitute event.
Cancellations must be made in writing to firstname.lastname@example.org more than 5 business days before the event and will be assessed a $350 conference setup fee. Cancellations will not be accepted if notice is received fewer than 5 business days before the event. For more information regarding administrative policies, complaints and cancellations, please contact us at 800.372.1033, or e-mail email@example.com.
Bloomberg BNA offers a hardship policy for CPAs and other tax and accounting professionals who wish to attend our live conference and seminars. Individuals must earn less than $50,000 annually in order to qualify. For individuals who are unemployed or earning less than $35,000 per year, a full discount off the price of registration for the program will be awarded. Individuals earning between $35,000 and $50,000 per year will receive a 50% discount off the price of the program. If an individual wishes to submit a case for hardship, he or she must contact Bloomberg BNA directly at firstname.lastname@example.org.
Please include the following information with your request: complete contact information, program for which a hardship reduction is being requested, requested amount for hardship reduction, and reason for applying for hardship. Please note that requests will not be considered until 30 days from the program date and that individuals may only apply for a hardship reduction once within a 12-month period. Bloomberg BNA reserves the right to make a final determination on a case-by-case basis. Our decision for granting a hardship is final and submission does not constitute acceptance.
Continental breakfasts, lunches, refreshment breaks, Bloomberg BNA Portfolio, and course materials in electronic format.
All Bloomberg BNA treatises are available on standing order, which ensures you will always receive the most current edition of the book or supplement of the title you have ordered from Bloomberg BNA’s book division. As soon as a new supplement or edition is published (usually annually) for a title you’ve previously purchased and requested to be placed on standing order, we’ll ship it to you to review for 30 days without any obligation. During this period, you can either (a) honor the invoice and receive a 5% discount (in addition to any other discounts you may qualify for) off the then-current price of the update, plus shipping and handling or (b) return the book(s), in which case, your invoice will be cancelled upon receipt of the book(s). Call us for a prepaid UPS label for your return. It’s as simple and easy as that. Most importantly, standing orders mean you will never have to worry about the timeliness of the information you’re relying on. And, you may discontinue standing orders at any time by contacting us at 1.800.960.1220 or by sending an email to email@example.com.
Put me on standing order at a 5% discount off list price of all future updates, in addition to any other discounts I may quality for. (Returnable within 30 days.)
Notify me when updates are available (No standing order will be created).
This Bloomberg BNA report is available on standing order, which ensures you will all receive the latest edition. This report is updated annually and we will send you the latest edition once it has been published. By signing up for standing order you will never have to worry about the timeliness of the information you need. And, you may discontinue standing orders at any time by contacting us at 1.800.372.1033, option 5, or by sending us an email to firstname.lastname@example.org.
Put me on standing order
Notify me when new releases are available (no standing order will be created)