Kickoff Panel June 6: The U.S. Tax Agenda and Its Impact on Transfer Pricing


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 U.S. system needs reform make long-term planning difficult.

The opening session at the Bloomberg BNA/Baker & McKenzie Transfer Pricing Conference will examine the status of the U.S. 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. Transfer pricing items in the Obama administration’s 2013 budget include:

a proposal to currently tax excess returns from transfer of intangibles to affiliates in low-tax jurisdictions, also contained in a tax reform discussion draft released in October by House Ways and Means Committee Chairman David Camp (R-Mich.);
a proposal to change the definition of intangibles under Sections 367(d) and 482 to include workforce in place, goodwill, and going concern; and
an earnings stripping proposal that would limit the deductibility, under Section 163(j), of interest paid by expatriated entities to related entities.

Panelists will include moderator Josh Odintz of Baker & McKenzie in Washington, D.C.; Ray Beeman, tax counsel and special adviser to the House Ways and Means Committee; David Hughes, tax adviser to the Senate Finance Committee; Steven Hannes of McDermott, Will & Emery in Washington, D.C.; and Rocco Femia of Miller & Chevalier in Washington, D.C.


Molly Moses
Managing Editor, Transfer Pricing Report