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Canada - U.S. Transfer Pricing Symposium


October 23 - 23, 2013
Toronto, ON
Product Code: TMC116
$795.00 Regular Price
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A one-day advanced/intermediate level session with live group instruction on Canada and U.S. cross-border transfer pricing developments affecting multinationals today.Canada Update

Course Level: Intermediate Delivery Method: Live Group

LEARNING OBJECTIVES

After attending this event, participants will be able to:
• Describe transfer pricing methodologies in Canada
• List pros and cons of Advance Pricing Agreements (APAs)
• Discuss cross-border service charges under the latest Sec. 482 service regulations
• Evaluate cost sharing and intangible transfers
• Identify trends in utilizing arbitration
• Understand the latest IRS cost sharing regulations

PREREQUISITES

As a prerequisite to attending this course, attendees are recommended to attend our U.S. Transfer Pricing Primer or an equivalent transfer pricing course.

All paid attendees will receive the Bloomberg BNA Portfolio: #7050, Business Operations in Canada

*One Portfolio per paid attendee. Quantities are limited.

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.

The Westin Harbour Castle
1 Harbour Square
Toronto, ON M5J 1A6
Canada
Tel: +1 416-869-1600

Limited Time Reduced Rate:
Single/Double $259.00
Triple $289.00
Quad $319.00

Our block of discounted sleeping rooms is limited, so please reserve your sleeping room early! We cannot guarantee rates or availability. Please contact the hotel and mention that you are attending the course listed under Bloomberg BNA. This limited-time discounted rate will be available up to 30 days prior to the meeting, or until the group block is sold-out, whichever comes first. Please note: your sleeping room is not included in the registration fee. 

WEDNESDAY, OCTOBER 23RD

8:00 am Registration and Continental Breakfast

8:30 am Welcome and Chair Introduction - Sandra Goldberg, Ernst & Young LLP, Ottawa

8:45 am Current Trends in Canada and U.S. Transfer Pricing Rules
• Review of transfer pricing methodologies in Canada – comparison of Canada, OECD and U.S. requirements
• Use of transfer pricing studies for satisfying the documentation requirements
• Comparison of TP policies and penalty provisions in Canada and the United States

9:45 am Hot Transfer Pricing Issues in Canada for U.S. Companies
• Royalties
• Business restructuring and IP migration
• Cost sharing and intangible transfers
• Recharacterization
• Services/permanent establishments
• Financial transactions and guarantee fees

11:00 am Refreshment Break

11:15 am U.S. Transfer Pricing Strategies for Canadian Companies
• Role of transfer pricing in preparing financial statements – FIN 48 – implementation steps
• Use of transactional v. profit-based pricing methods – special issues involving U.S. distributors of Canadian suppliers
• Avoiding the U.S. penalty provisions under Sec. 6662(e) – update on the latest U.S. court decisions
• Understanding the latest IRS cost sharing regulations
• Determining cross-border service charges under the latest Sec. 482 service regulations

12:30 pm LUNCHEON

1:30 pm Managing the Audit
• Preparing for the CRA – what the agents are looking for on audit
• Dealing with the IRS International Examiner - maintaining contemporaneous supporting documentation for IRS audits

2:45 pm Refreshment Break

3:00 pm Resolution of Cross-Border Transfer Pricing Disputes
• Assessing the options for resolving Transfer Pricing disputes
• Trends in utilizing arbitration
• Procedures for obtaining US and Canadian Mutual Assistance relief
• Pros and cons of Advance Pricing Agreements (APAs)
• Latest litigation developments, strategies and policies in Appeals involving tax controversies

4:15 pm Closing Comments – What You Should Take Home From This Meeting

4:30 pm Meeting Ends


Times/Topics Subject to Change

Copyright Bloomberg BNA 2013



EDUCATIONAL COURSE CREDIT


UP TO 8 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 8 CPE 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.