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Government and Industry Leaders Demystify Complex Cost-Sharing Regulations in One Day Seminar

NEWS RELEASE

Contacts:
Mark Carrington
(703) 341.5880
mcarrington@bna.com

Arlington, Va. (January 15, 2009) – Arlington, VA (January 14, 2009) Leaders from the IRS and Treasury will explain and answer questions on the recently-filed cost-sharing regulations in “The Present and Future of Cost Sharing” – a full-day in depth seminar on the new cost sharing regulations. Experts from the government and private industry will pose the questions, discuss their implications and suggest coping strategies for both U.S. and foreign multinationals. Beyond the temporary regulations, there will be a full discussion of the grandfather rules, and what the IRS is looking for in its audits of pre-existing cost sharing arrangements explained by the IRS official in charge of such audits. The event will be cosponsored by BNA Tax & Accounting, publisher of Transfer Pricing Report, and the prominent law firm Alston & Bird LLP in the firm’s Washington, DC office, February 19.

“These temporary regulations became effective on January 5, 2009, and the detailed rules therein now govern new cost sharing arrangements, new transfers of “platform intangibles” (with an exception that is less than it seems) and to a certain extent all existing cost sharing arrangements. In addition, sooner or later the new regulations will affect transfer pricing rules for royalty transactions, reports Robert T. Cole, a leading authority on transfer pricing issues and Chair of the event. “Given the complexity of these regulations, ‘knowing only the basics’ simply isn’t an option for corporations with or considering cost sharing and their advisors.”

What do these cost sharing regulations mean? How do they impact me? And what are effective approaches for different scenarios? These questions and more will be explained by leading authorities, including:

Stephen A. Musher, Associate Chief Counsel (International), IRS; Michael McDonald, International Economist, Office of Tax Analysis, Department of Treasury; Kenneth Christman, Attorney, Branch 6, Office of Associate Chief Counsel (International), IRS; Robert Weissler, Senior Counsel, Advance Pricing Agreement Program, IRS; Patricia C. Chaback, Industry Director, Office of Communications, Technology & Media, Large & Mid-Size Business Division, IRS; Janice L. Lucchesi, Vice-President- Tax, Akzo Nobel, Inc., Henry J. Birnkrant, Alston & Bird, LLP; David Canale, Ernst & Young, and Tim Reichert, Ph.D., Managing Director, Duff & Phelps, LLC

The agenda will cover: Overview of Temporary Regulations; Definitions and Rules for CSAs and Non-CSAs; “Platform Contribution Transactions” including the detailed rules on how to select among and apply the authorized methods; Periodic Adjustments; Grandfather Rules, Record Keeping and Reporting Requirements; Audits and what IRS will accept for preexisting arrangements; Coping with the Temporary Regulations, including repairing strategies, APAs; FIN 48.

The seminar (CLE credits available) will be held February 19, from 8:30 am – 6:30 pm (including lunch and networking reception) at Alston & Bird LLP, 950 F Street, NW, Washington DC, 20004. To register, go to http://tmstore.bna.com or call 800.372.1033. Sign up by February 2 for Early-Bird Registration ($750 Early Bird Registration; $600 BNA Subscribers; $400 Government/Academic rate (for full-time employees of the government, academia, or full-time students).

BNA is the foremost publisher of print and electronic news, analysis, and reference products. BNA publications intensely cover legal and regulatory developments for professionals in business and government. BNA is the oldest wholly employee-owned company in the United States, and produces more than 350 news and information services — including Daily Labor Report and Daily Tax Report — widely respected for comprehensive and objective reporting and analysis.

Alston & Bird LLP was established in 1893 and has offices in Atlanta, Charlotte, Dallas, Los Angeles, New York, North Carolina’s Research Triangle, Silicon Valley, Ventura County, and Washington, D.C., The firm’s 800 attorneys provide a full range of worldwide services to domestic and international clients. Our International Tax Practice Group has been among the leaders in developing transfer pricing methodologies that both facilitate cross-border operations and satisfy the tax authorities of the United States and foreign countries, and creating innovative substantive and procedural solutions to resolve transfer pricing controversies.

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BNA is the leading independent publisher of print and electronic news and information for professionals in business and government. BNA produces more than 300 news services, including the highly respected Daily Labor Report, U.S. Law Week,and Daily Report for Executives. Visit BNA online at www.bna.com