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Accounting for Income Taxes: UTPs in Transfer Pricing


Product Code - TMW92
Speaker(s): Christopher Desmond, Michelle Johnson, and Mark Schuette, Duff & Phelps
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All registrants of this webinar will receive a complimentary copy of Bloomberg BNA Portfolio 5004, Accounting for Income Taxes: Uncertain Tax Positions in Transfer Pricing (a $400 value).

A company’s transfer pricing matters impact the single largest (and typically most risky) expense item: tax. Not only does the company’s ASC 740-10 analysis of transfer pricing uncertain tax positions (“UTPs”) cover U.S. federal positions, it also includes global and state and local positions. As a result, the treatment of transfer pricing issues under ASC 740-10 can have a significant impact on a company’s stock price, corporate credit rating, and reputation.

This new practical webinar from Bloomberg BNA, Accounting for Income Taxes: UTPs in Transfer Pricing presented by Christopher Desmond, Michelle Johnson, and Mark Schuette, provides advisors with a greater understanding of the relationship between UTPs and transfer pricing, as well as, practical guidance on dealing with uncertain tax positions.

During this live webinar, Desmond, Johnson, and Schuette will cover:

  • Brief overview of transfer pricing and the relative importance of transfer pricing UTPs.
  • Which stakeholders need to know about ASC 740-10 and transfer pricing, including their responsibilities.
  • How to identify transfer pricing UTPs, including:
    • Defining a Unit of Account for transfer pricing UTPs under ASC740-10;
    • Identifying and documenting transfer pricing UTPs; and
    • Applying initial filters to determine materiality of transfer pricing UTPs.
  • Recognition of UTPs related to transfer pricing.
  • Measurement analysis related to ASC 740-10.
  • How audit firms are using ASC740-10 to perform tax provision reviews.
  • Current trends surrounding ASC 740-10 and best practices being used by companies.

Educational Objectives

  • Understand the framework for analyzing UTPs as required by ASC 740-10.
  • Assess the stakeholder group, including all of the participants involved with preparing, reviewing and approving a company’s accounting treatment of UTPs related to transfer pricing under ASC 740-10.
  • Review the steps taken to identify transfer pricing UTPs, including those that are generated by intercompany transactions that should exist, but do not.
  • Interpret the Recognition step requirements of ASC 740-10 as they apply to the unique characteristics of transfer pricing UTPs.
  • Apply the ASC 740-10 requirements on measurement, including the development of scenarios and assignment of probabilities, to quantify the tax benefit associated with transfer pricing UTPs.

Who Should Attend?

  • Transfer Pricing Managers
  • Directors of Transfer Pricing
  • Directors of International Taxes
  • Senior Managers of International Tax
  • Managing Directors
  • Directors of Accounting
  • Finance Managers
  • Tax Directors
  • Accounting Managers
  • Sr. Tax Mgrs - Audits and Planning
  • Managing Directors – International Tax Strategy
  • Principal Tax Accountants
  • Senior Managers of International tax

Prerequisite: None
Level: Intermediate to Advanced
Delivery method: Group Internet live
Recommended CPE credit: 1.5 credits 

Christopher Desmond, Michelle Johnson, and Mark Schuette, Duff & Phelps

Christopher Desmond joined Duff & Phelps in 2012. He has been named as one of the world’s leading transfer pricing professionals by Legal Media Group and has served on multiple transfer pricing teams involving transfer pricing audits and support in the US Federal Tax Courts. Throughout his career, he has led initiatives related to global and domestic supply chain transfer pricing policies for various industries and company size. Christopher has experience working with clients in the agricultural, alcohol and tobacco, consumer products, commodity trading, automotive, medical devices, healthcare, pharmaceutical, hotel, retail, food and beverages, logistics, publishing, technology, media, mining, consumer goods, industrial products and specialty chemicals industries.

Christopher was previously with Ceteris, where he helped build the company into a world-class organization by serving as Managing Director and Chief Sales Officer. Prior to joining Ceteris, Christopher was a transfer pricing economist with both PricewaterhouseCoopers LLP and Ernst & Young LLP. An award-winning speaker, he has spoken at numerous conferences and seminars throughout the nation as well as authored articles and chapters regarding transfer pricing for international publications. Christopher co-authored the BNA Tax Management Portfolio on Accounting for Uncertain Tax Positions in Transfer Pricing under ASC 740-10 (FIN 48) published in 2012.

Christopher has also guest lectured at several Universities including Georgetown Law School and Chicago Booth MBA Program. He obtained his MBA with a concentration in International Business and a Bachelors of Science in Management from Eastern Illinois University.

Michelle Johnson joined Duff & Phelps in 2012. A managing director, Michelle has significant experience advising clients on transfer pricing and valuation matters – including ASC 740 (FIN 48) recognition and measurement analyses, advanced pricing agreements, cost-sharing analyses, buy-in valuations, supply chain restructuring and tangible and intangible transfer pricing documentation. She has consulted with companies in such wide-ranging industries as financial services, technology, pharmaceuticals, retail and many others.

Previously, Michelle led the development of Ceteris’ FIN 48 service line and pioneered several thought leadership publications on behalf of the firm. She is an award-winning speaker and has presented at numerous conferences and seminars regarding transfer pricing issues. She served as co-editor of Wolter Kluwer’s Guide to International Transfer Pricing: Law, Compliance and Tax Planning Strategies, and co-authored the BNA Tax Management Portfolio on Accounting for Uncertain Tax Positions in Transfer Pricing under ASC 740-10 (FIN 48) published in 2012.

Michelle obtained her Masters degree in Economics from New York University and a BS in Economics and French from the University of Illinois.

Mark Schuette joined Duff & Phelps in 2012 as a managing director with over 25 years of experience consulting with clients on business accounting, tax and valuation issues. Prior to joining Duff & Phelps, Mark was a managing director at Ceteris, where he led the southeast region for the company. Mark was previously with Ernst & Young for ten years, where he was the Partner-in-Charge of the Southeast Transfer Pricing and Economics practice. In this role he conducted transfer pricing studies for global companies located across a six-state region. He is regularly sought out for his expertise with state and local tax transfer pricing matters. Mark also has more than five years experience providing litigation services to attorneys and their clients, including preparing for and participating in trial depositions, as well as delivering expert witness testimony.

Mark holds an MBA in Finance and a BBA in Accounting from Loyola University of Maryland. He is a member of the American Institute of Certified Public Accountants. Mark is a frequent speaker on transfer pricing topics and co-authored the BNA Tax Management Portfolio on Accounting for Uncertain Tax Positions in Transfer Pricing under ASC 740-10 (FIN 48) published in 2012.