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.
- Build a fundamental knowledge of international transfer pricing
- Develop an understanding of the U.S. transfer pricing regulations, the Internal Revenue Code section 482, 367, 1059A and other sections
- Become familiar with the regulatory provisions for intangibles, and disputes and their resolution (or avoidance)
- Gain practical insights for effective tax risk management
Number of MCLE Hours: USD School of Law is a State Bar of California-approved provider of MCLE and Legal Specialization in Taxation Law credits and certifies that this activity is approved for 10.75 hours of general MCLE and 10.75 hours of Legal Specialization in Taxation Law.
Who Should Attend: 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.
Course Materials: Suggested Readings - 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.
Instructor: David N. Bowen, LLM in Litigation and Dispute Resoluton, Principal, Grant Thornton LLP. David is Grant Thornton’s national leader for the Transfer Pricing practice located in Washington, D.C. He is a leading International Transfer Pricing Expert and National Managing Principal for Grant Thornton’s U.S. Transfer Pricing Practice, and Chair, Global Tax Advisory Committee, Grant Thornton International. He has 28 years of experience in wide variety of complex tax and commercial litigation matters, including 11 years with Baker & McKenzie and 4 years with the IRS. He is a Law Professor, Transfer Pricing, University of Florida Graduate Tax Program (LL.M) and Law Professor, George Washington University, LAW 6682 International Dispute Resolution (LL.M.).