March 25 – 26, 2014
Day One – 1:00 PM – 5:00 PM
Day Two – 8:00 AM – 5:00 PM
10 MCLE Hours*
For professionals new to Transfer Pricing or have added responsibilities that include Transfer Pricing, a thorough 1 and 1/2 day course will give attendees a deeper understanding of the fundamental legal rules, economic concepts, and strategies for planning, documenting, and implementing Transfer Pricing and preparing for any controversy issues.
Learn from a top practitioner and experienced expert.
Transfer Pricing Course Overview
Instructor: David N. Bowen, National Managing Principal, Transfer Pricing Services, Grant Thornton LLP, Washington, D.C. and Instructor at the University of Florida.
This course provides a practical, historical, and theoretical understanding of international transfer pricing, with exposure to related areas of taxation. Coverage includes (i) Internal Revenue Code section 482, 367, 1059A, and other sections, (ii) the basic structure, theory, organization, and content of the U.S. Treasury Regulations, (iii) non-U.S. approaches, including OECD and U.N. guidance, (iv) penalties, (v) controversies, dispute resolution, and avoidance, (vi) theory versus practice (with practical suggestions for effectively managing the tax risks associated with international transfer pricing transactions.
Reading suggestions appear below. These include statutes, regulations, case law, and other materials. To the extent possible, we will try to “go green” by relying on electronic retrievals for the citations. Please note: New developments arise frequently in international transfer pricing. Thus, we will supplement this agenda as we progress, as appropriate or necessary.
- The Basics
- Understanding the U.S. Transfer Pricing Regulations
- The Regulatory Provisions for Intangibles
- Disputes and their Resolution (or Avoidance)
- International Aspects
- Putting It all Together
*University of San Diego School of Law is a State Bar of California approved MCLE provider and certifies that this activity is approved for 10.0 hours of general credit.