American Conference Institute’s 4th Cross-Industry Forum on

Global Transfer Pricing

Wednesday, March 25, 2009

About

There has never been a more important time to attend ACI’s one-of-a-kind Global Transfer Pricing forum

From the Senate Finance Committee threatening “full-fledged” tax reform in 2009 to the increase and complexity in audits by foreign taxing authorities, multinational companies are faced with the challenge of trying to keep up to date on changes in transfer pricing rules globally. All of this has led to an increase in cross-border tax disputes. Countries that previously did not enforce transfer pricing regulations are now emerging as major players in the transfer pricing world, and as a result in-house tax professionals and transfer pricing specialists at multi-national companies have little to no room for error. In order for your company to avoid substantial penalties and stay competitive, you need an intensive, up-to-the-minute review of the most pressing issues that arise in global transfer pricing.

The answer is ACI’s 4th Annual Cross-Industry Forum on Global Transfer Pricing, a must-attend event for all international tax and transfer pricing specialists. Through a distinguished faculty of top tax and legal experts, including in-house transfer pricing specialists from Caterpillar, Citigroup, Gucci, Intel, Rolls Royce, Siemens, and UPS, this two-day conference will provide even the most seasoned transfer pricing specialists with current information and clarity on overcoming today’s most complex transfer pricing challenges on a region-by-region and country-by-country basis.

Contents & Contributors

About

There has never been a more important time to attend ACI’s one-of-a-kind Global Transfer Pricing forum

From the Senate Finance Committee threatening “full-fledged” tax reform in 2009 to the increase and complexity in audits by foreign taxing authorities, multinational companies are faced with the challenge of trying to keep up to date on changes in transfer pricing rules globally. All of this has led to an increase in cross-border tax disputes. Countries that previously did not enforce transfer pricing regulations are now emerging as major players in the transfer pricing world, and as a result in-house tax professionals and transfer pricing specialists at multi-national companies have little to no room for error. In order for your company to avoid substantial penalties and stay competitive, you need an intensive, up-to-the-minute review of the most pressing issues that arise in global transfer pricing.

The answer is ACI’s 4th Annual Cross-Industry Forum on Global Transfer Pricing, a must-attend event for all international tax and transfer pricing specialists. Through a distinguished faculty of top tax and legal experts, including in-house transfer pricing specialists from Caterpillar, Citigroup, Gucci, Intel, Rolls Royce, Siemens, and UPS, this two-day conference will provide even the most seasoned transfer pricing specialists with current information and clarity on overcoming today’s most complex transfer pricing challenges on a region-by-region and country-by-country basis.

Contents & Contributors

Incorporating Current OECD Approaches to Taxation of Multinationals Into Your Company’s Transfer Pricing Policy
Marc M. Levey, Partner, Baker & McKenzie (New York, NY)

A Proven Transfer Pricing Roadmap on Navigating and Complying With the New U.S. Service Regulations
Tayanita Hayes, Attorney – Tax, Caterpillar Inc. (Peoria, IL)
Ward Connolly, Partner, Fenwick & West LLP (Mountain View, CA)

To be Audited or Not to be Audited?: Reducing the Likelihood of Contentious Audits and Resolving Them When They Do Occur
Reeves Westbrook, Partner, Covington & Burling LLP (Washington, DC)
Kristine Riisberg, Senior Manager, Deloitte Tax LLP (New York, NY)


Global Transfer Pricing in Emerging Markets: Analyzing and Complying with Regional Variations in the Regulatory Framework
China, Japan, South Korea and other selected Asian Countries - “From a Corporate Viewpoint”
Stanley Sherwood, International Tax Counsel, Gucci Group (New York, NY)

Moderator & Canada
Elinore Richardson, Partner, Borden Ladner Gervais LLP (Toronto, Canada)

Latin America & Mexico
Moises Curiel-Garcia, Tax Director, Baker & McKenzie (Mexico City, Mexico)

India
Parul Jain, Nishith Desai Associates (Mumbai, India)

Europe
Bart van der Gulik, Stibbe New York B.V. P.C. (New York, NY)

How and When to Institute an Advanced Pricing Agreement to Help Your Company Manage Risks and Avoid Disputes
Maurice Agresta, Vice President Taxation, United Parcel Service of America, Inc. (UPS) (Atlanta, GA)
Henry Birnkrant, Partner, Alston & Bird LLP (Washington, DC)

Maneuvering Your Way Through the Competent Authority Process
Brian Gleicher, Partner, White & Case LLP (Washington, DC)
Darrin Litsky, Transfer Pricing Specialist, Deloitte Tax LLP (New York, NY)

The Resurgence of Arbitration: The Different International Treatments of It, How to Prepare for It, and When It’s Most Useful
Emin Toro, Partner, Covington & Burling LLP (Washington, DC)

Treatment of Intangibles: Valuation and Marketing of Intangibles in Cross-Border Transactions
Brian Andreoli, Partner, DLA Piper (New York, NY)



DOCUMENT TYPES: PPT PPTM DOC PRESENTATIONS AVAILABLE: 11

7:30
Registration and Coffee
8:05
Opening Remarks from Chair
Mr. Marc Levey
Partner
Baker & McKenzie
Mr. Richard Goldberg
Director of Global Transfer Pricing
Citigroup‚ Inc.
8:15
Incorporating Current OECD Approaches to Taxation of Multinationals Into Your Company's Transfer Pricing Policy
Mr. Richard Goldberg
Director of Global Transfer Pricing
Citigroup‚ Inc.
Mr. Marc Levey
Partner
Baker & McKenzie
1 file
Discussion of the OECD Paper on Business Restructuring
4.1 MB 30 pages Presentation
PPT - Discussion of the OECD Paper on Business Restructuring
9:25
Morning Coffee Break
9:40
A Proven Transfer Pricing Roadmap on Navigating and Complying With the New U.S. Service Regulations
Ms. Tayanita Hayes
Attorney - Tax
Catepillar‚ Inc.
1 file
NAVIGATING AND COMPLYING WITH THE NEW U.S. SERVICES REGULATIONS
3.4 MB 21 pages Presentation
PPT - NAVIGATING AND COMPLYING WITH THE NEW U.S. SERVICES REGULATIONS
Mr. Ward Connolly
Partner
Fenwick & West LLP
1 file
Navigating and Complying with the New U.S. Service Regulations
850 KB 52 pages Presentation
PPT - Navigating and Complying with the New U.S. Service Regulations
10:50
Adapting to New Cost Sharing Regulations
Mr. Neal Kochman
Partner
Caplin & Drysdale
Mr. Gregory Barton
Partner
Mayer Brown LLP
12:00
Networking Luncheon for Attendees and Speakers
13:15
To be Audited or Not to be Audited?: Reducing the Likelihood of Contentious Audits and Resolving Them When They Do Occur
Mr. Reeves Westbrook
Partner
Covington & Burling
Ms. Kristine Riisberg
Senior Manager
Deloitte Tax LLP
1 file
To be Audited or Not to be Audited?
300.5 KB 40 pages Presentation
PPT - To be Audited or Not to be Audited?
14:30
Afternoon Refreshment Break
14:45
Global Transfer Pricing in Emerging Markets: Analyzing and Complying with Regional Variations in the Regulatory Framework
Mr. Stanley Sherwood
International Tax Counsel
Gucci Group
1 file
GLOBAL TRANSFER PRICING IN EMERGING MARKETS
1.1 MB 63 pages Presentation
PPT - GLOBAL TRANSFER PRICING IN EMERGING MARKETS
15:20
Global Transfer Pricing in Emerging Markets: Analyzing and Complying with Regional Variations in the Regulatory Framework
Ms. Elinore Richardson
Partner
Borden Ladner & Gervais
1 file
GLOBAL TRANSFER PRICING IN EMERGING MARKETS: ANALYZING AND COMPLYING WITH REGIONAL VARIATIONS IN THE REGULATORY FRAMEWORK
2.3 MB 30 pages Presentation
PPT - GLOBAL TRANSFER PRICING IN EMERGING MARKETS:ANALYZING AND COMPLYING WITH REGIONALVARIATIONS IN THE REGULATORY FRAMEWORK
Mr. Moises Curiel-Garcia

Baker & McKenzie
1 file
GLOBAL TRANSFER PRICING IN EMERGING MARKETS: ANALYZING AND COMPLYING WITH REGIONAL VARIATIONS IN THE REGULATORY FRAMEWORK
2.3 MB 30 pages Presentation
PPT - GLOBAL TRANSFER PRICING IN EMERGING MARKETS:ANALYZING AND COMPLYING WITH REGIONALVARIATIONS IN THE REGULATORY FRAMEWORK
Mr. Bart van der Gulik

Stibbe New York B.V. P.C.
1 file
GLOBAL TRANSFER PRICING IN EMERGING MARKETS: ANALYZING AND COMPLYING WITH REGIONAL VARIATIONS IN THE REGULATORY FRAMEWORK
2.3 MB 30 pages Presentation
PPT - GLOBAL TRANSFER PRICING IN EMERGING MARKETS:ANALYZING AND COMPLYING WITH REGIONALVARIATIONS IN THE REGULATORY FRAMEWORK
Paul Jain

Nishith Desai Associates
1 file
GLOBAL TRANSFER PRICING IN EMERGING MARKETS: ANALYZING AND COMPLYING WITH REGIONAL VARIATIONS IN THE REGULATORY FRAMEWORK
2.3 MB 30 pages Presentation
PPT - GLOBAL TRANSFER PRICING IN EMERGING MARKETS:ANALYZING AND COMPLYING WITH REGIONALVARIATIONS IN THE REGULATORY FRAMEWORK
17:45
Conference Adjourns
7:30
Continental Breakfast
8:00
Chairs Remarks
8:15
How and When to Institute an Advanced Pricing Agreement to Help Your Company Manage Risks and Avoid Disputes
Mr. Maurice Agresta
VP Taxation
UPS
1 file
An Advance Pricing Agreement to Manage Risks and Avoid Disputes
639 KB 32 pages Presentation
PPT - An Advance Pricing Agreement to Manage Risks and Avoid Disputes
Mr. Henry Birnkrant
Partner
Alston & Bird
1 file
An Advance Pricing Agreement to Manage Risks and Avoid Disputes
639 KB 32 pages Presentation
PPT - An Advance Pricing Agreement to Manage Risks and Avoid Disputes
9:25
Morning Coffee Break
9:40
Maneuvering Your Way Through the Competent Authority Process
Mr. Brian Gleicher
Partner
White & Case
1 file
Maneuvering Your Way Through the Competent Authority Process
592 KB 45 pages Presentation
PPT - Maneuvering Your Way Through the CompetentAuthority Process
Mr. Darrin Litsky
Transfer Pricing Specialist
Deloitte Tax LLP
1 file
Maneuvering Your Way Through the Competent Authority Process
592 KB 45 pages Presentation
PPT - Maneuvering Your Way Through the CompetentAuthority Process
10:50
The Resurgence of Arbitration: The Different International Treatments of It‚ How to Prepare for It‚ and When It's Most Useful
Mr. Emin Toro
Partner
Covington & Burling
2 files
The Resurgence of Arbitration: The Different International Treatments of It, How To Prepare for It, and When It Is Most Useful
122.5 KB 40 pages Presentation
PPTM - The Resurgence of Arbitration:  The Different International Treatments of It, How To Prepare for It, and When It Is Most Useful
Avoiding Double Taxation Through Binding Arbitration: A Comparative Review
155 KB 3 pages White Paper
DOC - Avoiding Double Taxation Through  Binding Arbitration:  A Comparative Review
12:00
Networking Luncheon for Attendees and Speakers
13:15
Treatment of Intangibles: Valuation and Marketing of Intangibles in Cross-Border Transactions
Brian Andreoli
Partner
DLA Piper
1 file
Treatment of Intangibles: Valuation and Marketing of Intangibles in Cross-Border Transactions
1.1 MB 24 pages Presentation
PPTM - Treatment of Intangibles:  Valuation and Marketing of Intangibles in Cross-Border Transactions
14:15
Conference Ends - Master Class Registration