Transfer Pricing Symposium
DAY ONE – Thursday, April 23
7:45 – 8:15 AM: Registration and Breakfast
8:15 – 8:30 AM: Welcome Remarks
Co-Chairs: John I. Forry, Director of U.S. Law Program for International Legal Professionals and Professor-in-Residence, University of San Diego School of Law School; and David Bowen, National Transfer Pricing Practice Leader, Grant Thornton LLP, Washington, DC
8:30 – 10:15 AM: OECD BEPS Action Items - Update
- What is BEPS?
- Recently published guidance on Transfer Pricing (Intangibles, Documentation, Dispute Resolution)
- Practical guidance for tax executive and professional service providers
Panelists: Steve Wrappe, National Leader for Transfer Pricing Dispute Resolution, KPMG, John I. Forry, Director of U.S. Law Program for International Legal Professionals and Professor in Residence, University of San Diego Law School, Laura Clauser, IRS Senior Field Economist (Invited), Alan Granwell, Of Counsel, Sharp Partners P.A.
Moderator: Marc Levy, Partner, Baker & McKenzie, New York, NY
10:15 – 10:45 AM: Break
10:45– 12:15 PM: Guarantees, Indemnities and Risk Shifting Considerations
- What are the transactions, and are they compensable?
- Court decisions (Canada, India)
- Pricing theories and considerations (ABA Task Force, Other - including whether the transactions involve "costs")
- Third party beneficiaries, privity of contract, and risk-shifting considerations
Panelists: Ken Christman, Executive Director, EY, Katherine Kimball, Principal, Deloitte LLP, Brad Rolph, Partner, Tax Service Line Leader – Southern Ontario, Canada, National Transfer Pricing Leader
Moderator: Mike Heimert, Managing Director, Transfer Pricing, Duff & Phelps
12:15 – 1:30 PM: Lunch
1:30 – 3:15 PM: Current TP Litigation: A Presentation – drawing from notable Transfer Pricing court cases of alternative perspectives of the IRS, the taxpayer, and the judge with the panel members undertaking alternating roles.
Panelists: Marc Levy, Partner, Baker & McKenzie, New York, NY, Mark Oates, Partner, Baker & McKenzie, Chicago, IL, Paul Dau, Counsel, McDermott Will & Emery LLP
Moderator: J. Clark Armitage, JD, Caplin & Drysdale, Washington, DC, and former IRS APA Program Deputy Director
3:15 – 3:45 PM: Break
3:45 – 5:00 PM: Transfer Pricing Wish List: What Corporations Want and Desire for Transfer Pricing Planning and Compliance
- Wish List from the Inside: A Corporate Tax Executive’s View of Transfer Pricing Rules Regulations, Guidelines, and Procedures
- A Level Playing Field – Simplification, Clarity, Certainty, Management, and Compliance
- The Ideal or Paradigm – Compliance, reporting, dispute avoidance, dispute Resolution, Information Systems
Panelists: Charles Middleton, Sr. Vice-President of Tax, Oxbow, Dick McAlonnan, Director of National Tax Transfer Pricing Controversy, EY, Alan Granwell, Of Counsel, Sharp Partners P.A.
Moderator: Mark Hoose, Managing Tax Counsel, Phillips 66
DAY TWO – Friday, April 24
8:30 – 8:45 AM: Welcome Remarks and Breakfast
Co-Chairs: John I. Forry, Director of U.S. Law Program for International Legal Professionals and Professor in Residence, University of San Diego Law School; and David Bowen, National Transfer Pricing Practice Leader, Grant Thornton LLP, Washington, DC
8:45 – 10:15 AM: Academic Research in Transfer Pricing and Relevance to the Practitioner
- Remarks on the usefulness academic Transfer Pricing research to the practitioner
- Relevance of Legal Academic Research on Transfer Pricing Regulations and Disputes
- The Role of Academic Experts in Transfer Pricing Litigation
Panelists: Christian Plesing, Professor, University of Copenhagen, Yariv Brauner, Professor, University of Florida, Bin Zhou, Principal, Brattle Group
Moderator: Russ O’Haver, Clinical Professor, Northeastern University, and Ernst & Young Transfer Pricing Partner
10:15 – 10:45 AM: Break
10:45 – 12:30 PM: Good Corporate Citizenry: Concepts, Considerations and Consequences
- What Does it Mean to Be a “Good Corporate Citizen” in Transfer Pricing – Theory, Application, Reality
- The Role of Morality in Corporate Governance – Transfer Pricing Implications
- Recommendations and Best Practices
Panelists: Corrie Blough, Vice-President, Tax, NuVasive, Inc., Jessica Weinberg, Director of Tax, Qualcomm (Invited), Craig Sharon, Partner, Bingham McCutchen LLP, Kara Boatman, Tax Principal, Economic and Valuation Services, KPMG
Moderator: Randy Free, Partner, International Tax Practice Leader West Region, Grant Thornton
12:30 – 12:45 PM: Closing Remarks and Symposium Summary
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 9.75 hours of general MCLE and 9.75 hours of Legal Specialization in Taxation Law.
Who Should Attend: Designed for professional service providers in global tax, finance, accounting and legal areas.