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BUS-X811L Transfer Pricing Symposium

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Course Description

3rd Annual

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, Alan Granwell, Of Counsel, Sharp Partners P.A., Katherine Horton-O’Brien, Principal, Transfer Pricing, Washington National Tax, PwC

Moderator: Marc Levey, Partner, Baker & McKenzie, New York, NY

10:15 – 10:45 AM: Break

10:45– 12:15 PM: Risk Shifting Considerations: Economic Viewpoints

  • Third party versus related party risk
  • What are the transactions, and are they compensable?
  • Examples of risk-shifting transactions
  • Strengths and limitations of different economic approaches to price risk

Panelists: Philippe Penelle, Principal, Deloitte LLP, Brad Rolph, Partner, National Transfer Pricing Leader, Grant Thornton Canada, Kevin Kiyan, Executive Director, Transfer Pricing, EY

Moderator: Mike Heimert, Managing Director, Transfer Pricing, Duff & Phelps 

12:15 – 12:55 PM: Lunch

1:00 –1:45 PM Key-Note Presentation: "A View from the Top: Current Transfer Pricing Topics (Substance, Procedure, and Administration) J. David Varley, Acting Director, Transfer Pricing Operations, Large Business & International Division, IRS

1:45 – 3:30 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 Levey, Partner, Baker & McKenzie, New York, NY, Paul Dau, Of Counsel, McDermott Will & Emery LLP, Tim Reichert, President & CEO, Economic Partners, LLC

Moderator: J. Clark Armitage, Caplin & Drysdale, Washington, DC, and former IRS APA Program Deputy Director

3:30 – 4:00 PM: Break

4:00 – 5:15 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 Carbon, Mark Freed, Director of Global Transfer Pricing, Intel Corporation, Lynn Anderson, Director, Transfer Pricing & International Tax, Edwards Lifesciences; Jon Jenni, Sr. Director, Transfer Pricing, BDO

Moderator: Alan Granwell, Of Counsel, Sharp Partners, P.A.


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: 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: Craig Sharon, Partner, Ernst & Young; Frank Rork, Senior Director, International Tax, Edwards Lifesciences;  Mark Freed, Director of Global Transfer Pricing, Intel Corporation;

Moderator: Randy Free, Partner, International Tax Practice Leader West Region, Grant Thornton

10:15 – 10:45 AM: Break

10:45 – 12:30 PM: Academic Research in Transfer Pricing and Relevance to the Practitioner

  • Current academic Transfer Pricing research projects and relevance to the practitioner
  • Relevance of Legal Academic Research in Transfer Pricing Regulations and Disputes
  • The Role of Academic Experts in Transfer Pricing Litigation

Panelists:  Christian Plesner Rossing, Associate Professor, Copenhagen Business School; Yariv Brauner, Professor, University of Florida; Bin Zhou, Principal, Brattle Group

Moderator:  Russ O’Haver, Clinical Professor, Northeastern University, and EY Transfer Pricing Partner

12:30 – 12:45 PM: Closing Remarks and Symposium Summary

Learner Outcomes

See program above.

Course Details

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: Designed for professional service providers in global tax, finance, accounting and legal areas.

Applies Towards the Following Certificate(s), Professional Programs and Series


  BUS-X811L - 002 Transfer Pricing Symposium      
  2015 - SP   Status:  Available
Classroom:   Thu 7:45AM - 5:00PM
23 Apr 2015
Classroom:   Fri 8:30AM - 12:45PM
24 Apr 2015
Class Schedule: 2 Sessions
Course Fee(s):
BUS Course Fee credit (1 units)   $895.00
  Available for Extension Credit: 1 units
Location:   Main Campus
Course Format:  Classroom