This dynamic two-day event will feature government officials and transfer pricing practitioners. You’ll have multiple networking opportunities, receive first-hand updates on best practices, interact with the most informed global transfer pricing specialists in industry and practice, and obtain the latest insights on transfer pricing trends and legislation, including:
| 8:00 - 9:00 am |
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Registration and Breakfast |
| 9:00 - 9:15 am |
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Welcome and Opening Remarks from Bloomberg BNA and Baker & McKenzie |
| 9:15 - 10:30 am |
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The 2012 US Tax Agenda and Its Impact on Transfer Pricing
Josh Odintz, Baker & McKenzie (Washington, DC), Moderator
Panelists: Ray Beeman (Tax Counsel and Special Advisor, House Ways and Means Committee), David Hughes (Tax Advisor, Senate Finance), Steven Hannes, McDermott Will & Emery (Washington, DC), and Rocco Femia, Miller & Chevalier (Washington, DC)
Multinational companies attempting to plan for the future face the unprecedented challenges of a continuing global economic crisis and a constantly changing tax law environment. The pressure for added tax revenues and the perception that the present US system needs reform make long-term planning difficult. This opening session will kick off the conference with a look at the status of the US agenda for tax reform in an election year along with an update on pending legislation and anticipated Treasury guidance and their collective impact on the future of transfer pricing. |
| 10:30 - 10:45 am |
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Refreshments |
| 10:45 - 12:15 pm |
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The Challenges of Transfer Pricing for Management Fees, Guarantees, and Other Intra-Group Financings
Russ Young, Baker & McKenzie (Chicago), Moderator
Panelists: Steven A. Musher, Associate Chief Counsel (International), IRS; Holly McClellan, GE Capital; Al Meghji, Osler Hoskin & Harcourt (Toronto); Peter Blessing, Shearman & Sterling; John Hughes, Manager, APMA Program, IRS
This session will provide an update on issues arising from the intercompany pricing of management fees and intra-group financing. Issues continue to arise globally with regard to what appear to be straight forward transactions, and this panel will focus its discussion on the stringent conditions that multinational companies have to face in many jurisdictions to deduct certain intercompany service charges and best practices for minimizing the possibility of double taxation. The group will also discuss options for intra-group financing and the pricing of guarantee fees, which continue to draw attention from various tax authorities. |
| 12:15 - 1:45 pm |
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Lunch
Keynote Address: 2011 Accomplishments and Priorities for the Future
Samuel Maruca, Transfer Pricing Director, LB&I, IRS |
| 1:45 - 3:00 pm |
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OECD Developments and The Future of Global Transfer Pricing
Mary Bennett, Baker & McKenzie (Washington, D.C.), Moderator
Panelists: Joseph Andrus, Head of Transfer Pricing Unit, CTPA Tax Treaty, Transfer Pricing and Financial Transactions Division—pending, OECD; Caroline Silberztein, Baker & McKenzie (Paris)
During this session, current and past OECD officials will provide an update on key OECD transfer pricing developments and address the future of global transfer pricing in a world where many jurisdictions are looking for revenue from increasingly limited sources. The discussion will include an update on the recent OECD intangibles project, the status of continuing OECD analysis of transfer pricing issues relating to emerging countries, and other hot topics. |
| 3:00 - 3:15 pm |
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Refreshments |
| 3:15 - 4:30 pm |
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Managing and Surviving Global Transfer Pricing Disputes
A. Duane Webber, Baker & McKenzie (Washington, DC), Moderator
Panelists: Mark March, Raytheon Company; Clisson Rexford, Akzo Nobel; Salim R. Rahim, Baker & McKenzie (Washington, DC)
Multinational companies are increasingly facing transfer pricing controversies in a variety of jurisdictions. This session will involve a discussion of hot transfer pricing topics that are the subject of disputes in key jurisdictions and options for successfully resolving such disputes. The session will also address best practices for proactively addressing transfer pricing issues and preparing for disputes before they arise. |
| 4:30 - 4:45 pm |
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Refreshments |
| 4:45 - 6:00 pm |
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Transfer Pricing Developments in Emerging Economies
Carol Dunahoo, Baker & McKenzie (Washington, DC), Moderator
Panelists: Michael Danilack, Deputy Commissioner (International), IRS; Archie Parnell, Managing Director, Goldman Sachs (Asia) and Alpana Saksena, Director, Global Transfer Pricing Services, KPMG LLP
To end the first day of the conference, this engaging session will examine recent developments in transfer pricing in the emerging economies through the eyes of government officials, practitioners and company representatives. The panel will consider emerging transfer pricing issues and challenges and opportunities for tax administrations and domestic and cross-border dispute resolution, with a focus on practical experiences and future perspectives. |
| 6:30 pm |
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Reception |
| 8:00 - 9:00 am |
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Breakfast |
| 9:00 - 10:00 am |
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Cost Sharing Today: Implementing and Defending a Cost Sharing Arrangement
John M. Peterson, Jr., Baker & McKenzie (Palo Alto), Moderator,
Panelists: Christopher Bello, Branch Chief, Branch 6, Associate Chief Counsel (Int’l), IRS;
Michael McDonald, Office of Tax Policy, Treasury Dept.); Daniel J. Frisch, Horst Frisch
Companies continue to implement cost sharing structures, and this session will focus on the impact of the new cost sharing regulations and issues arising from planning and implementing a cost sharing structure. The session will further address issues arising from the audit of such structures and experiences with handling various disputes involving cost sharing arrangements. |
| 10:00 - 10:15 am |
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Refreshments |
| 10:15 - 11:15 am |
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Update on 367(d) and Non-Cost Sharing Intangible Property Transfers
James M. O’Brien, Baker & McKenzie (Chicago), Moderator
Panelists: David Ernick, Associate International Tax Counsel, Treasury Dept.; Markell Fluckiger, Senior Vice President, The Western Union Company; John B. Magee, Bingham & McCutchen (Washington, DC)
In addition to cost sharing, other structures are put in place to move intangible assets offshore. This session will address (1) the current treatment of certain intangibles under Code section 367(d); (2) whether intangibles are compensable from a US tax perspective; (3) key issues arising from an outbound transfer of intangible property from the US in a non-cost-sharing context; (4) latest pronouncements from the Service; and (5) key valuation issues. The discussion will also address current challenges to licensing transactions in Ireland and Puerto Rico and their impact on supply chain restructurings. |
| 11:15 - 12:15 pm |
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The Economics of Transfer Pricing
Richard Boykin, Baker & McKenzie (Palo Alto, CA & Washington, DC), Moderator
Panelists: Bill Morgan, Senior Economist, Transfer Pricing, Operations, LB&, IRS; Robert Schweihs, Willamette Management Associates; Timothy A. Reichert, Economics Partners; Dr. Stephan Schnorberger, Baker & McKenzie (Dusseldorf)
This esteemed panel of top transfer pricing economists will discuss cutting edge issues with the newly-appointed LB&I Chief Economist, including IP valuation issues, the potential use of CUTs for various intercompany transactions, and the treatment of loss making entities in constructing arm’s length ranges. |
| 12:15 - 1:45 pm |
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Lunch
Keynote Address by Michael Danilack, LB&I Deputy Commissioner (International), IRS |
| 1:45 - 2:45 pm |
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The New Advance Pricing and Mutual Agreement Program: Update on the Integration and Case Management Today
Melinda Phelan, Baker & McKenzie (Houston), Moderator;
Panelists: Richard McAlonan, Director, APMA Program, IRS; Chris Czarka, Director –Tax & Trade, Nissan North America; Matthew Frank, GE; Craig Sharon, Bingham McCutchen; Marc Levey, (Baker & McKenzie New York)
During the past year, the APA and Mutual Agreement programs at the IRS have been merged into the new APMA program under the direction of the new Transfer Pricing Director, Samuel Maruca. This session will describe the combined entity and update taxpayers on the benefits and burdens associated with the new APMA program. |
| 2:45 pm |
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Close of Conference |
Please note that agenda items and times are subject to change.
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. If your state society is not a NASBA member, please let us know what state(s) you practice in so we can obtain approval. 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. This program with live group instruction is nontransactional which is appropriate for newly admitted attorneys.
Substitutions/Cancellations: Cancellations received more than 72 hours prior to the meeting will be issued a credit. A $150 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 1.800.372.1033 or bnatax@bna.com. Credits will not be issued for “no-shows.”
Conference Materials: All Conference program materials are available for purchase for those unable to attend our live conferences. Orders placed for conferences that have not yet taken place will be shipped no earlier than 2-3 weeks after the conference has concluded. Payment must be received in full before material orders can be fulfilled.