Second Annual Transfer Pricing Symposium Schedule (March 27 and 28, 2014)

First Annual Transfer Pricing Symposium Schedule (March 7 and 8, 2013)

DAY ONE

7:45 – 8:30 AM      Registration and Continental Breakfast

8:30 – 9:00 AM      Welcome, Introductions, and Opening Remarks

John Forry, JD, Director of Tax Programs and Professor-in-Residence, University of San Diego School of Law; and Russ O’Haver, PhD, Clinical Professor, Northeastern University School of Business and former Transfer Price Practice Leader, Ernst & Young LLP, New York

9:00 – 10:15 AM    US-Mexico Transfer Pricing Tax Policy & Enforement Developments

• Impact of IRS Reorganization of Transfer Pricing Resources (including an overview of the current structure) and Mexico TP Administration Structure
• Regional coordination among tax authorities & "Big TP Issues"
• TP controversy/enforcement trends (including APA and MAP cases)

Panelists: John Hinding, Deputy Associate Chief Counsel (Strategic International Projects), IRS, Washington, D.C.; Sergio Luis Pérez, Head of the Transfer Pricing Audit Team, Servicio de Administración Tributaria (SAT); Thomas Vidano, JD, Deputy Division Counsel (International), Office of Division Counsel, Large Business & International (LB&I)

10:15 -10:45 AM    Break and Refreshments

10:45 – 12:15 PM   Legal Issues and Trends in Transfer Pricing

• Reactions to regulatory panel (APMA reorganization)

• Significant recent cases (Alterra, Amazon, Eaton)
• Controversy/audit trends (joint audits, UTPs)
• International trends and agreements (OECD and UNTPM)
• Why is Transfer Pricing so hard?

Panelists:  Paul Dau, JD, McDermott Will & Emery LLP, International Transactions and Federal Tax Controversies, Silicon Valley, CA; Mike Patton, JD, LLM, partner in Tax practice, DLA Piper LLP, Los Angeles, CA; Craig Sharon, JD, former APA Director and Partner, Bingham McCutchen LLP, Washington, DC; Moderator: Kenneth Christman, Executive Director, National Transfer Pricing Practice, Ernst & Young LLP, Washington, D.C.

12:i5 – 1:30 PM    Lunch

1:30 – 2:30 PM      Economic Effects and Their Impacts on Transfer Pricing

• Regional controversy perspectives, new techniques, ERP/Supply Chain/IP migration
• Advanced economic techniques/issues for transfer pricing planning with a focus on marketing intangibles
• Services transaction issues (embedded high value intangibles) and measurement
• Structure of Appeals relative to the use of economic analysis
• Presenting economic analysis in a controversy setting (best practices & future directions)

Panelists: Oscar Burakoff, Economist in Tax Practice, DLA Piper LLP, San Diego, CA; Mike A. Denning, Ph.D., Principal, Transfer Pricing/Economics, Ernst & Young LLP; Josh Walls, Director, Duff and Phelps, Los Angeles; John Young, Senior Transfer Pricing Economist, IRS Appeals; Moderator: Russ O’Haver, Northeastern and former New York TP practice leader, Ernst & Young LLP


2:30 – 3:00 PM     Break

3:00 – 4:15 PM     Mexican Transfer Pricing Developments

• Learn how the change in Transfer Pricing administration within Mexico may lead to shifts in Transfer Pricing policy and/or enforcement
• Understand the purpose, role and standards of a transfer pricing study for Mexican purposes and how these differ from studies prepared for US purposes
• Understand intellectual property migration and supply chain tax planning are viewed by the Mexican Transfer Pricing officials

Panelists: Jorge Castellon, Transfer Pricing practice leader, Ernst & Young LLP, Mexico; Sergio Luis Pérez Head of the Transfer Pricing Audit Team, Servicio de Administración Tributaria (SAT); Guillermo Villaseñor-Tadeo, Partner, Sanchez Devanny

4:15 – 5:15 PM     Supply Chain/IP Planning for Transfer Pricing

• Designing and Implementing tax effective structures for global supply chain reorganizations
• OECD draft and impacts relative to “tiers” of LATAM countries
• Current issues in supply chain transfer pricing that affect International tax planning opportunities in Europe, Asia and Latin America
• Practical insights for the development of your transfer pricing policies

Panelists:  Randy Free, Tax Partner, Grant Thornton LLP; Ken Martin, International Tax Planning Director, Terex Corporation; Simon Somohano, Tax Partner and Leader of Transfer Pricing and Economic Consulting, Deloitte LLP, Latin America and the Caribbean region

DAY TWO

8:30 – 9:45 AM    Transfer Pricing Academic Research and the Practitioner

• Survey directions of applied and theoretical academic research in transfer pricing
• APA and audit risk research (US, Canada, Japan)
• “Dual” transfer pricing  and optimal royalty structure research
• Bridging academic research with practitioner interests (and vice versa)
  

Panelists: Susan Borkowski, PhD, Professor of Accounting and joint faculty in the Integrated Science, Business and Technology Program, La Salle University; Nicole Johnson, PhD, Assistant Professor of Accounting, UC Berkeley Haas School of Business; Moderator: Russ O’Haver, PhD, Northeastern University

9:45 -10:15 AM    Break

10:15 – 11:45 PM  Industry/Corporate Panel Discussion
• Corporate tax director perspectives on regulatory change and controversy trends (APAs, MAP and cost sharing cases
• Shared experiences in transfer pricing planning opportunities, documentation issues, and controversy trends for technology focused companies
• Mini-case study for Operational (ERPor Systems based) Transfer Pricing:  need, implementation team structure, challenges and best practices/lessons learned
• Economic incentives and the alignment of reporting and managerial interests relative to Transfer Pricing Structure

Panelists: Mark Hoose, JD, LLM, Tax Counsel, Phillips 66; Brian Lynn, JD, LLM in Taxation, Senior Tax Counsel, Hewlett-Packard Company [Technology]; Greg Rocco, Transfer Pricing Supervisor, Ford Motor Co.; Kathrin Zoeller, Senior Director Transfer Pricing, Weatherford Group, formerly with News Corporation; Moderator: David Bowen, Principal, Grant Thornton LLP and Clinical Professor, University of Florida

12:00 – 1:00 PM    Lunch and Closing Symposium Observations