CD of a Teleconference with an Q&A
The IRS’ new temporary regulations on transfer pricing are positive for business despite the IRS’ belief that companies are improperly moving income attributed to U.S. intangible assets off shore for taxation.
The amendments to Reg. 1.482 address new transfer pricing methods for controlled service transactions. They extend through 2007 a safe harbor that lets companies charge out certain low-margin services at cost, without a markup, as long as they can show these services don’t significantly contribute to key competitive advantages.
Listen as our panel of experienced tax attorneys analyzes all key aspects of the new IRS regulations on international transfer pricing and reveals their opportunities for taxpayers.
The panel includes:
Brian Becker is president and CEO of Precision Economics Inc., a Washington-based transfer pricing consulting practice. He holds a doctorate and master’s degrees in economics from the Wharton School at the University of Pennsylvania. Brian consults on transfer pricing issues for both the IRS and large corporate clients and is an active writer and speaker on the topic.
Alan Granwell is a partner in the Washington office of the DLA Piper law firm. He has been practicing in international taxation for more than 35 years. Alan formerly was an international tax counsel and director of the Treasury Department’s Office of International Tax Affairs.
Valerie Amerkhail is director of transfer pricing services at Economic Consulting Services in Washington. She consults with international tax attorneys on IRS field examps, advanced pricing agreements and documentation reports pertaining to a wide range of consumer and industrial products. Previously in her career, Valerie was a partner at Coopers & Lybrand and an analyst with the Congressional Budget Office.
Patricia Lewis is a member in the Washington office of the Caplin & Drysdale law firm. She has been with the firm nearly continuously since 1971 and her practice focuses on international transfer pricing and advance pricing agreement issues. Patricia is a former member of the IRS commissioner’s advisory group and has had numerous articles on transfer pricing published in professional journals.
You’ll be thoroughly briefed and fortified to help clients:
- Leverage the cost safe harbor for the rest of this year
- Work within the new “business judgment” rule, which applies only to the controlled group, not to every group member
- Find a way to share services among related business entities when those services aren’t eligible for the cost safe harbor
- Meet the IRS’ revised documentation standards
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TELECONFERENCE CD
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