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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 Forry, JD, Director of U.S. Law Program for International Legal Professionals and Professor-in-Residence, University of San Diego School of Law; and David Bowen, JD, 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 (confirmed)

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: Invited Transfer Pricing Experts

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 Amazon) 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; Dan Frisch, Managing Partner, Horscht & Frisch, Washington DC (Invited); and Irving Plotkin, Managing Partner, PricewaterhouseCoopers, Boston, MA (Invited)

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

  • Transfer Pricing information management
  • "Operational Transfer Pricing"
  • Financial reporting considerations

Panelists: Invited Transfer Pricing Experts

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


DAY TWO – Friday, April 24

8:30 – 8:45 AM: Welcome Remarks and Breakfast

Co-Chair: John Forry, JD, Director of U.S. Law Program for International Legal Professionals and 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: Invited Noted Academic Researchers in Transfer Pricing

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: Good Corporate Citizenry: Concepts, Considerations and Consequences

  • Wish list from the inside: a corporate Transfer Pricing director’s view of operational TP, knowledge management and incentives
  • The proper role of economics in Transfer Pricing

Panelists: Corrie Blough, Vice-President, Tax, NuVasive, Inc.; Jessica Weinberg, Director of Tax, Qualcomm (Invited); Charles Middleton, Sr. Vice-President of Tax, Oxbow; Dick McAlonnan, Director of National Tax Transfer Pricing Controversy, EY; and Craig Sharon, Partner, Bingham McCutchen LLP

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

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


  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