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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, 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

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 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.


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




Sections

  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
Potential Discount(s):
BUS PD - Save 10%! 4 Week Early Registration
  Available for Extension Credit: 1 units
Location:   Main Campus
Course Format:  Classroom