POSTPONED: The 7th Annual USD School of Law Transfer Pricing Symposium

POSTPONED: The 7th Annual USD School of Law Transfer Pricing Symposium

Date and Time

  • Thursday, April 2, 2020 from 8:30 a.m. to 6:15 p.m.
  • Friday, April 3, 2020 from 8:30 a.m. to 12:15 p.m.

Location

Joan B. Kroc Institute for Peace and Justice, Theatre

5998 Alcala Park San Diego, CA 92110

Cost

$0-$395

Details

The Seventh Annual USD Transfer Pricing Symposium is postponed to a date to be announced.

Those that have purchased tickets will be refunded.

Please keep an eye out for the new dates and we look forward to seeing you in San Diego for an exciting Transfer Pricing Symposium.

The Seventh Annual USD School of Law Transfer Pricing Symposium brings together top-level transfer-pricing professionals, in a unique "one-of-a-kind" format.  The Symposium combines panel and roundtable discussions with live simulations and role playing, all conducted or performed by highly experienced practitioners.  This year, the Symposium also includes high-level discussions on a wide variety of topics, including Advanced Economic Approaches and Theorems, a Regulatory Roundup, specific-country discussions (e.g., "who is open for business?"), a simulated and complex trilateral Competent Authority case (including arbitration considerations), peer-group discussions, and other Special-Panel Topics, including Ethics in Transfer Pricing, and the future for "Tax Talent."

Also, for the first time, the Symposium will offer attendees the opportunity to develop a hoped-for "wish list" of statutory, regulatory, or written-guidance suggestions.  To round out the Symposium, we will discuss future formats and topics, so that the Eighth-and-forward Symposiums remain fresh on the cutting edge of top-level transfer pricing collaborations and discussions.  

If you have general questions, please contact: usdlawevent@sandiego.edu

REGISTRATION INFORMATION

  • General Admission - $395
  • USD Faculty & Students - Free (registration required)

Register Here

  • Agenda (subject to change)
      Thursday, April 2, 2020  
    7:45 AM Registration & Continental Breakfast Rotunda
    8:20 AM Opening Remarks Theatre
    8:30 AM

    The Future of Tax Competition
    Chair: Kathrin Zoellar, Weatherford International, LLC

    Which countries are competitive? Which are open for business? A roundtable discussion that compares and contrasts various tax jurisdiction's approaches to transfer pricing, from a tax competition perspective.

    Theatre
    9:30 AM

    Pillars
    Chair: Mariel Reissig, KPMG

    What are the optimal or best practices for MNE transfer pricing given the new OECD pronouncements on the digital economy.

    Theatre
    10:15 AM Break Rotunda
    10:30 AM

    Vignette - "The Good, the Bad, and the Ugly - A TP Trilogy"
    Chair: Kelly Granado, Grant Thornton, LLP

    Taking a single fact pattern, experienced transfer-pricing practitioners three different ways of handling a transfer-pricing matter, thus illustrating the good (effective risk management and dispute avoidance), the bad (ineffective issue management), and the ugly (a complete breakdown in the corporate transfer-pricing function).

    Theatre
    11:30 AM

    Working Parties
    Chair: J. Clark Armitage, President, Caplin & Drysdale

    Here, the audience is divided into 5-6 "Working Parties," each of whom is tasked with devising and voicing the Working Party's suggestions for regulatory reform or amendment, administrative procedures or pronouncements, OECD action or draft, or other matters designed to augment or improve upon existing regulations and guidance.  After discussion, each group will present their proposals or suggestions to a three-person panel, tasked with formulating a suggested 2020 governmental TP business plan.

    Theatre

    12:15 PM

    Lunch

    ABC

    12:45 PM

    Keynote Address: The Future of Tax Talent
    Adam Golden, TaxSearch, Inc

     
    1:40 PM

    Advanced Transfer Pricing Economics, Part I
    Chair: Kevin Kiyan, Andersen Tax

    A special panel of leading transfer-pricing economists, who will present and robustly debate three cutting-edge economic concepts in transfer pricing.  This panel will feature the very highest level of transfer pricing economic theory and practice, and suggest practical cross-border MNE applications.

    Theatre
    2:10 PM

    Break

     
    2:20 PM

    Advanced Transfer Pricing Economics, Part II
    Chair: Kevin Kiyan, Andersen Tax

    A special panel of leading transfer-pricing economists, who will present and robustly debate three cutting-edge economic concepts in transfer pricing.  This panel will feature the very highest level of transfer pricing economic theory and practice, and suggest practical cross-border MNE applications.

    Theatre
    3:10 PM

    Case Law Revisited and Re-litigated
    Chairs: Morgan Lewis Trial Team

    The Transfer Price Symposium has always featured the ever-popular Moot Court session, in which highly experienced tax litigators present actual Tax Court cases (and more recently, a hypothetical case) in a live, role-playing format.  In a new twist to this session, we ask the question, what if that older case had been governed by, and litigated under, current (i.e., new or newer) U.S. and international regulations and guidance?

    Theatre
    5:30 PM Local Vintage California Sunset Cocktail Reception Garden of the Sea
     

    Friday, April 3, 2020

     
    7:45 AM Continental Breakfast Rotunda
    8:00 AM

    Breakfast Down Under *new*
    Chair: Lorena Sosa, Grant Thornton Australia

    Ms. Sosa will provide viewpoints and updates based on the upside-down view of the world - down under.

    Theatre
    8:30 AM

    Stock Options - "What's Up With That?"
    Chair: Ed Froelich, Morrison Foerster

    A continuation of the transfer pricing litigation in the Tax Court - this time, however, centering on the special considerations and procedures surrounding expert witness testimony. Since in the Tax Court, the report of the expert witness constitutes the direct testimony, this session will focus primarily on effective cross-examination of the expert witness (or witnesses). As with Part 1, the participants will ideally reserve time to explain and comment upon their goals and objectives in connection with the expert.

    Theatre
    9:30 AM

    Mini Case Study - RNPs and the Trilateral Case, Part I
    Chair: Sean Foley, KPMG

    Here, the audience is divided into three groups - this time, however, each group receives the same set of facts, and after consultation and analysis, presents its case to a CA Analyst for the U.S., Canada, and "Country Y" [to be determined].  That presentation, in turn, should assist each CA in formulating the CA's RNP (recommended negotiating position).

    Theatre
    10:30 AM

    Break

     
    10:45 AM

    Mini Case Study - RNPs and the Trilateral Case, Part II
    Chair: Sean Foley, KPMG

    Part II: In a live role-playing session, those three CA Analysts then meet to discuss and resolve the case on a trilateral basis - if possible.  This session likely will demonstrate the challenges that CA Analysts face in achieving the treaty-based goals of avoiding or relieving double (and perhaps triple) taxation.

    What happens if the case cannot be resolved?  A discussion of litigation and arbitration alternatives and possibilities.

    Theatre
    11:30 AM

    Ethics CLE
    Chair: Burgess J. William Raby, Raby Law Offices

     
    12:30 PM

    CLOSING REMARKS & SYMPOSIUM ADJOURNED

    Theatre
  • Continuing Education

    MCLE

    USD School of Law is a State Bar of California-approved provider of MCLE. Please check back for the total amount of CLE credits that will be offered.

    CPE

    This organization follows the CE guidelines specified in the California Board of Accountancy Regulations. Please check back for the total amount of CPE credits that will be offered.

     

     

  • WHO SHOULD ATTEND

    Designed for professional service providers in global tax, finance, accounting and legal areas, this intensive day-and-a-half symposium provides an excellent opportunity for you to engage the experts on legal and economic trends impacting transfer pricing compliance, planning, and controversies.

Sponsor(s)

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Post Contact

USD Law School External Relations
usdlawevent@sandiego.edu