3rd Annual Cross-Industry Forum on

Global Transfer Pricing

Creating, Administering, and Defending a Tax-Efficient System for Multi-National Corporations and Entities

Wednesday, May 16, 2007

About

Perhaps responding to the recent $3.4 billion settlement by a major pharmaceutical company with the IRS, companies are increasingly shifting transfer pricing responsibilities to their in-house tax professionals. In the meantime, tax authorities around the world have stepped up the transfer pricing requirements, especially in what constitutes sufficient documentation to support a transfer pricing report. With the increasing spread of penalty and examination regimes in international taxation in many countries, as well as the heightened scrutiny of common strategies for reducing effective tax rates, in-house tax professionals’ responsibilities are larger than ever. ACI’s Global Transfer Pricing publication is designed to give you an understanding of how to minimize tax expense on market capitalization, and help you satisfy the multiplicity of requirements in the countries in which your company conducts business.

Transfer pricing experts will offer you the most accurate and comprehensive information available in this specialized area. You will leave this seminar equipped to:

  • Implement the new IRS 482 cost sharing regulations
  • Take transfer pricing controversies head on by successfully navigating international APA Programs, and Competent Authority processes
  • Correctly allocate company assets to permanent establishments under the new OECD guidelines
  • Keep track of the rules of new players to global transfer pricing arena to minimize cost of compliance

Contents & Contributors

About

Perhaps responding to the recent $3.4 billion settlement by a major pharmaceutical company with the IRS, companies are increasingly shifting transfer pricing responsibilities to their in-house tax professionals. In the meantime, tax authorities around the world have stepped up the transfer pricing requirements, especially in what constitutes sufficient documentation to support a transfer pricing report. With the increasing spread of penalty and examination regimes in international taxation in many countries, as well as the heightened scrutiny of common strategies for reducing effective tax rates, in-house tax professionals’ responsibilities are larger than ever. ACI’s Global Transfer Pricing publication is designed to give you an understanding of how to minimize tax expense on market capitalization, and help you satisfy the multiplicity of requirements in the countries in which your company conducts business.

Transfer pricing experts will offer you the most accurate and comprehensive information available in this specialized area. You will leave this seminar equipped to:

  • Implement the new IRS 482 cost sharing regulations
  • Take transfer pricing controversies head on by successfully navigating international APA Programs, and Competent Authority processes
  • Correctly allocate company assets to permanent establishments under the new OECD guidelines
  • Keep track of the rules of new players to global transfer pricing arena to minimize cost of compliance

Contents & Contributors

Allocating for Intangibles to Ensure an Arm’s Length and Fair Market Value
Anthony J. Barbera Ph.D., A CRA International Company (Washington, DC)

New Considerations for Cost Sharing Under IRS 482
Henry J. Birnkrant, Alston & Bird (Washington, DC)
John B. Magee, McKee Nelson LLP (Washington, DC)
Charlene Unitan, Rolls-Royce North America Inc. (Chantilly, VA)

Audits, Adjustments and Disputes: Strategies for Resolving Transfer Pricing Controversies
Mark Freed, Intel Corporation (Santa Clara, CA)
Brian Andreoli, DLA Piper (New York)
Mindy Piatoff, KPMG LLP (Washington, DC)

Transfer Pricing Documentation: Getting it Right the First Time
Peter A. Barnes, General Electric Company (Fairfield, CT)

Permanent Establishments and the Allocation of Income: Compliance with New OECD Guidelines
Arthur Mendoza, Ernst & Young LLP (Washington, DC)

North American Transfer Pricing Update: Mexico
Moisés Curiel, Baker & McKenzie (Mexico City, Mexico)

Canadian Transfer Pricing Update – 2007
Salvador M. Borraccia, Baker & McKenzie (Toronto, Canada)

China, India, and Asia Pacific: An In-Depth Look at Increasingly Regulated Transfer Pricing Jurisdiction
Theresa K. Dilworth, Pfizer Inc. (New York)
Mark Freed, Intel Corporation (Santa Clara, CA)
Robert Green, Caplin & Drysdale (Washington, DC)

Applying European Transfer Pricing Regulations
Wolfgang Büttner, Tax Directorate (Berlin, Germany)
Werner Stuffer, Siemens AG (Munich, Germany)
Ted Keen, CRA International (London, UK)
Karl Wündisch, Wündisch Pharma Consult, (Berlin, Germany)

Ensuring an Efficient, Effective Corporate Transfer Pricing System
Marc M. Lewis, Sony Corporation of America (New York)
Dean Santucci, International Taxes Dover Corporation (New York)
John B. Magee, McKee Nelson LLP (Washington, DC)

Transfer Pricing for Intercompany Services: Living With Change
John P. Warner, Buchanan Ingersol & Rooney PC (Washington CD)
Steven C. Wrappe, Mayer, Brown, Rowe & Maw LLP (Washington DC)
Clark J. Chandler, KPMG (Washington DC)



DOCUMENT TYPES: PRESENTATIONS AVAILABLE: 0