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BUS-X811L Transfer Pricing Symposium

Course Description

2nd Annual Transfer Pricing Symposium 2014


Read Bios of Chairs, Moderators and Panelists

DAY ONE – Thursday, March 27

7:45 – 8:15 AM: Registration and Continental Breakfast

8:15 – 8:30 AM: Welcome Remarks

Co-Chairs: John Forry, JD, Professor-in-Residence, University of San Diego School of Law; and Russ O’Haver, PhD, Clinical Professor, Northeastern University School of Business and former Transfer Pricing Practice leader, Ernst & Young LLP, New York, NY

8:30 – 10:15 AM: United States, OECD and Emerging Transfer Pricing Markets: Regulatory and Controversy Directions

  • Transfer Pricing and US Congressional tax initiatives
  • Salient Transfer Pricing Issues and Developments from non-US jurisdictions
  • The UN’s Transfer Pricing guidance for emerging markets: similarities and differences

Panelists: Michael Kobetsky, PhD, Global Professor of Law, New York University Law School and member of the UN Transfer Pricing subcommittee on Transfer Pricing; Yoshio Uehara, Chairman of the TP Committee at the International Fiscal Association, Mexico; Kenneth W. Wood, JD, Senior Manager, Advanced Pricing and Mutual Agreement Program, IRS Tax Treaty Division

Moderators: David Bowen, LLM in Litigation and Dispute Resolution, Principal, Grant Thornton LLP, Washington, DC; and John Forry, JD, Director of Tax Programs and Professor-in-Residence, University of San Diego School of Law

10:15 – 10:45 AM: Break and Refreshments

10:45– 12:15 PM: OECD Chapter Six and Base Erosion Profit Shifting (BEPS)

  • What is BEPS? -- current directions from recently published guidance
  • Insights from current OECD level meetings
  • Practical relevance to the Transfer Pricing service provider and tax directors

Panelists: Richard Boykin, PhD, Economics, principal economist, Baker & McKenzie Global Transfer Pricing, Washington, DC; Ignacio Box, JD, Director, Hewlett-Packard TP Enhancement Initiative;  Craig Sharon, JD, National TP Office, Ernst & Young, Washington, D.C.

Moderator: Kenneth Christman, Jr., JD, LLM in Taxation, Executive Director, National Tax Transfer Pricing, Ernst & Young LLP, Washington, DC and former IRS Transfer Pricing Branch

12:15 – 1:30 PM: Lunch

1:30 – 3:15 PM: Current TP Litigation: a Presentation Drawing From Notable TP Court Cases (3M, Altera, BMC Software, Eaton And Intersport Fashion) of Alternative Perspectives of The IRS, the Taxpayer, and the Judge with the Panel Members Undertaking Alternating Roles

Panelists: Paul Dau, JD, McDermott Will & Emery LLP, International Transactions and Federal Tax Controversies, Palo Alto, CA; John Magee, JD, Partner, Bingham, McCutchen, Washington, DC; Anne A. Welsh, PhD, Principal, Transfer Pricing, Ernst & Young LLP, Seattle, WA

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: Special Topics in Transfer Pricing

  • What is “Operational Transfer Pricing”, what types of companies are adopting it and what are the benefits?
  • Current developments and tax authorities controversy positions on corporate treasury TP transactions

Panelists: Rodrigo Arana, Transfer Pricing, Terex; Jennifer Kohler, Senior Director of Global Implementation, ONESOURCE Operational Transfer Pricing, Thomson Reuters, New York, NY; Gregg Rocco, MBA, Transfer Pricing Supervisor, Ford Motor Corporation

Moderator: Randy Free, CPA, Tax Partner, Grant Thornton LLP, Irvine, CA


DAY TWO – Friday, March 28

8:30 – 8:45 AM: Welcome Remarks

Co-Chair: John Forry, JD, Professor-in-Residence, University of San Diego School of Law

8:45 – 10:15 AM: Academic Research in Transfer Pricing and Relevance to the Practitioner

  • Remarks on the usefulness of academic Transfer Pricing research to the practitioner
  • Literature survey of Transfer Pricing academic research
  • TP Knowledge Management Systems' research

Panelists: Susan Borkowski, PhD, Professor of Accounting and joint faculty in the Integrated Science, Business and Technology Program, LaSalle University, Philadelphia, PA; Christian Plesner Rossing, PhD, Assistant Professor, Department of Accounting and Auditing, Copenhagen Business School, Copenhagen, Denmark; Lisa De Simone, PhD, Assistant Professor of Accounting, Stanford Graduate School of Business, Palo Alto, CA

Moderator: Russ O’Haver, PhD, Clinical Professor, Northeastern University School of Business and former Transfer Pricing Practice Leader Ernst & Young LLP, New York, NY

10:15 – 10:45 AM: Break

10:45 – 12:30 PM: Practitioners’ Perspectives: Future Directions of Transfer Pricing Research and Application

  • Wish list from the inside: a corporate Transfer Pricing director’s view of operational TP, knowledge management and incentives
  • Cutting edge of economic technique and Transfer Pricing

Panelists: Veena Parrikar, PhD, Principal, BDO USA, LLP, San Francisco; Tim Reichert, PhD, Principal, Economic Partners Inc., Denver, CO; Jessica Weinberg, JD, Director, Tax, Qualcomm Incorporated; Kathrin Zoeller, MA, Senior Director Transfer Pricing, formerly with News Corp and presently with Weatherford Group

Moderator: Curt Kinsky, JD, Principal, Transfer Pricing practice and Western Region practice, Ernst & Young LLP, San Jose

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

  • Summarizing the major themes of the conference and practical implications

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

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