Day One 
  

8:00 am Registration and Continental Breakfast 
  

8:45 am Managing the Corporate Transfer Pricing Function

• How U.S. companies today are expected to comply with the Sec. 482 arm’s-length standard
• Developing a global compliance solution for related party transactions to mitigate penalty assessments
• Strategy policy and process implementation - integrating transfer pricing into corporate objectives/goals
• Documentation, management, and monitoring of corporate data - proactively managing risk
• Managing your in-house transfer pricing function including co-ordination with external advisors

10:15 am Refreshment Break 
  

10:30 am Analyzing the Intercompany Transfers of Tangible Property

• How to select and apply the Best Method Rule for intercompany transfers of tangible goods
• Advantages and limitations on the use of historic survey data – establishing an arm’s-length range
• Determining the tested party - conducting a strategic functional analysis
• How to determine when transactional methods (i.e., CUP, Resale Price, etc.) are more reliable than profit based methods (i.e., CPM)

12:15 pm LUNCHEON 
  

1:30 pm Arranging for Intercompany Transfers of Intangible Property

• Understanding the Sec. 482 rules for transfers of intangible property
• Methods for valuing royalty license fees and cost-sharing buy-in payments
• Current trends in IRS controversies involving cost-sharing and licensing arrangements after Veritas
• Discounted cash flows and the treatment of intangibles: let them expire, maintain them, or create/enhance/develop them
   

3:15 pm Refreshment Break 
  

3:30 pm Understanding the IRS Rules for Intercompany Services and Financial Products

• When  you must impute a profit or mark-up on service costs
• Available methodologies – use of cost-based charges
• Treatment of stewardship or other non-chargeable functions
• The business judgment rule
• How to benchmark intercompany loans, guarantees, cash pooling arrangements and other intercompany financial transactions   

5:00 pm Meeting Ends for the Day 
  

Day Two 
  

8:00 am Continental Breakfast 
  

8:45 am Global Documentation Strategies to Avoid Transfer Pricing Penalties

• Satisfying the rules for contemporaneous principal and background documentation using a Transfer Pricing Study
• Preparing a Transfer Pricing Study – verifying or modifying estimated targets for actual results
• How the 20% and 40% penalties are applied to the substantial or gross understatement of tax on an annual basis
• Understanding the exceptions to the Sec. 6662(e) penalty

10:00 am Refreshment Break 
  

10:15 am Interrelationships of IRS Audits with Financial Statement Preparation

• Disclosure of IRS audit results in financial statements
• Determining FIN 48 disclosure - determining the amount of Recognized Tax Positions
• Preparation of Schedule UTP for Uncertain Tax Positions – current status on implementation – planning issues
• Accruing interest and penalties on tax underpayments

11:15 am Understanding the APA Process

• The APA alternative: Negotiating a Successful Strategy
• Planning when or why to consider an APA
• Deciding whether Competent Authority is the right path
• The current CA environment

12:30 pm LUNCHEON 
  

1:30 pm Resolving IRS Transfer Pricing Controversies

• Verifying or measuring estimated transfer pricing charges – budget v. actual – making compensating adjustments
• Who handles the audit? - things the IRS economist will ask for on audit – dealing with the International Examiner (IE) – dealing with IRS counsel
• Tiering of issues- what is it?, how does it affect case resolution?, and how to resolve a tier issue
• Resolution strategies for exam-level settlements: fast track mediation, early referral and accelerated issue resolution (AIR) procedures
• Post examination resolution – Appeals and beyond

3:15 pm Meeting Ends

EDUCATIONAL COURSE CREDIT

Up To 14 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 14 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.