June 6 Panel: The Challenges of Transfer Pricing for Management Fees, Guarantees, and Other Intra-Group Financings.
With little in the way of formal guidance from the IRS or the OECD on the issue, expert panelists at the June 6-7 Bloomberg BNA/Baker & McKenzie transfer pricing conference will consider intercompany pricing of management fees, guarantees, and intragroup financing. The discussion will focus on the stringent conditions that multinational companies face in many jurisdictions to deduct certain intercompany service charges and the best practices for minimizing the possibility of double taxation.
Pricing of guarantees was at issue in The Queen v. General Electric Capital Canada Inc. While Canada’s Federal Court of Appeal held for the taxpayer, practitioners have expressed concern about the court’s consideration of implicit support received from the company’s U.S. parent. Panelists for this session—including one from GE and another who was lead counsel for the company in its case—have extensive experience with this topic.
The panel, moderated by Russ Young of Baker & McKenzie in Chicago, will include 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
Managing Editor, Transfer Pricing Report