The Future of U.S. Transfer Pricing — Is There One?

Baker McKenzie_logoWhile the specifics of the Trump Administration’s tax plan are in flux, the one certainty is that any significant change to the U.S. corporate tax code will trigger a host of complex decisions by multinational corporations and global tax authorities. Other countries will react legislatively and regulatory to the jettisoning of the U.S. 35 percent corporate tax rate. This will have significant consequences for multinational tax planning.

Will territoriality be a key component of tax reform? Will Subpart F rules be eliminated? Could a new destination-based cash flow tax regime change transfer pricing overnight?

Join us at the 7th Annual Bloomberg BNA and Baker McKenzie Global Transfer Pricing Conference: Washington, D.C. on June 7 & 8, 2017 to hear government officials from key jurisdictions, policy makers and leading industry experts and advisers discuss and debate contentious transfer pricing on the cusp of overhauling the U.S. international tax rules.

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Last year’s speakers included:

  • Barbara M. Angus, Republican Chief Tax Counsel, House Committee on Ways and Means
  • Christopher Bello, Chief, Branch 6, Office of the Associate Chief Counsel (International), IRS
  • Michael Bernard, US Tax Counsel, Microsoft Corporation
  • Ian Cremer, Head of Valuation, World Customs Organization
  • Margaretha Haeussler, Vice President Economic Analysis, Olympus Corporation of the Americas
  • J. Richard Harvey, Jr., Professor of Practice, Villanova University Charles Widger School of Law School and Graduate Tax Program
  • John Hickey, Director, Global Transfer Pricing, Johnson & Johnson
  • John Hughes, Senior Advisor – Transfer Pricing Operations, IRS
  • Brian Jenn, Attorney-Advisor, Office of International Tax Counsel, US Treasury
  • Aruna Kalyanam, Democratic Tax Counsel, House Committee on Ways and Means
  • Gert-Jan Koopman, Deputy Director-General for State Aid, European Commission
  • Holly McClellan, Director, Global Transfer Pricing, Tax Counsel, General Electric
  • Donna McComber, Assistant Director, Advance Pricing and Mutual Agreement Program, IRS
  • J. Todd Metcalf, Democratic Chief Tax Counsel, Senate Finance Committee
  • Saul Mezei, Partner, Morgan, Lewis & Bockius LLP
  • Paul Morton, Head of Group Tax, RELX Group plc
  • Carlos Pérez Gómez Serrano, Director of Transfer Pricing Audits, Mexican Tax Administration Service (SAT)
  • Damon V. Pike, President, The Pike Law Firm
  • Sharon Porter, Director, Treaty and Transfer Pricing Operations, IRS
  • Mark Prater, Republican Chief Tax Counsel, Senate Finance Committee
  • William J. Sample, Corporate Vice President - Worldwide Tax, Microsoft Corporation
  • Catherine Schultz, Vice President for Tax Policy, National Foreign Trade Council
  • Theodore Setzer, Assistant Deputy Commissioner - International, IRS
  • Richard W. Skillman, Member, Caplin & Drysdale,Ch., Washington, DC
  • Robert Stack, Deputy Assistant Secretary for International Tax Affairs, US Treasury
  • Oginan Stoichkov, Director, Global Transfer Pricing, PepsiCo, Inc.
  • Cheryl Teifer, Director of Field Operations – Transfer Pricing Practice, IRS
  • Mike Williams, Director of Business and International Tax, HM Treasury