This two day seminar is designed for corporate executives and tax advisers from law and accounting firms who deal with the latest technical transfer pricing issues. This includes VP taxes, tax directors, tax managers, controllers, treasurers, chief financial officers, and for lawyers and accountants who service their clients with transfer pricing problems and issues. An intermediate transfer pricing seminar or equivalent as a prerequisite is recommended before attending this course. This program is non-transitional, which is appropriate for experienced attorneys.

Course Level: Intermediate-Advanced; Delivery Method: Live Group

LEARNING OBJECTIVES

• Hear the Latest US Developments Related to Transfer Pricing including Litigation
• Understanding the Latest OECD Developments Related to Transfer Pricing
• Learn the Latest IP Migration Strategies
• Resolve Transfer Pricing Controversies Through Alternative Dispute Resolution Forums
• An Examination of the Service Regulations - An In-Depth Look

All paid attendees will receive the Bloomberg BNA Portfolio: #893 , Transfer Pricing: Litigation Strategy and Tactics

*One Portfolio per paid attendee. Quantities are limited.

PREREQUISITES

There are no prerequisites for attending this program.

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 customercare@bna.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 customercare@bna.com 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, such as complaints and cancellations, please contact us at 800.372.1033, or e-mail customercare@bna.com. 

Morgan Lewis Conference Center
101 Park Ave #40
New York, NY 10178
Tel: 212-309-6801
 

Hotel accommodations are at your own discretion.
We suggest the following: 

New York Helmsley: Tel: 212.490.8900
212 East 42nd St, New York, NY

Grand Hyatt: Tel: 212.883.1234
109 East 42nd St., New York, NY

Day One

8:00 am Registration and Continental Breakfast

9:00 am U.S. Developments Related to Transfer Pricing - Litigation Update and Other Developments

• Trends in Transfer Pricing Controversies
• IRS Reorganization of Large Business and International Division
• Recent Court Cases  

9:45 am OECD Developments Related to Transfer Pricing

• Overview of OECD Transfer Pricing Guidelines
• OECD IP Project
• Comparison with UN Transfer Pricing Initiatives

10:45 am Refreshment Break

11:00 am IP Migrations Today

• IP Migration Strategies
• IP Valuation Methods
• Potential for Controversies

12:15 pm Luncheon

1:15 pm Intercompany Pricing for Financial Transactions

• Pricing for Guarantees
• Hedging Transactions
• Loans and Cash Pools

2:45 pm Refreshment Break

3:00 pm Harmonizing Transfer Pricing Structures Post Acquisition

• Integrating Different Transfer Pricing Approaches
• Managing Section 6662 Documentation
• Combining IP Ownership

4:15pm Valuation for Financial Reporting versus Tax Purposes

• Summary of GAAP Valuation Rules
• Tax Valuation Methods
• Uses and Misuses of Valuation Methods

5:15 pm Meeting Adjourns for the Day

Day Two

8:00 am Continental Breakfast

9:00 am Resolving Transfer Pricing Controversies Through Alternative Dispute Resolution Forums

• Realignment of Advanced Pricing and Mutual Agreement Office
• Negotiating Advanced Pricing Agreements
• Competent Authority Developments

10:30 am Refreshment Break

10:45 am Transfer Pricing Risk Mitigation

• Pre-documentation Work: Agreements and Data
• Preparing Documentation
• Post-Documentation: Anticipating Tax Authority Positions

12:00 pm Luncheon

1:00 pm The Future of US Transfer Pricing  

2:30 pm Q&A

2:45 pm Seminar Concludes

EDUCATIONAL COURSE CREDIT

Up To 13.5 CPE Credit hours available

Bloomberg BNA is registered with the National Association of the State Boards of Accountancy as a sponsor of continuing professional education on the National Registry of CPE sponsors. State Boards of Accountancy have final authority on the acceptance of individual courses. Complaints regarding registered sponsors may be addressed to NASBA, 150 Fourth Avenue North, Suite 700, Nashville, TN 37219-2417.

Up to 13.5 CLE Credit hours available

Bloomberg BNA will apply for continuing legal education credits in any state or jurisdiction where available. For more information, please contact Bloomberg BNA customer service at 800.372.1033 and ask to speak to the CLE Accreditations Coordinator, or email us at accreditations@bna.com .

Hardship Policy

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 accreditations@bna.com. 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.