New IRS Rules for Transfer Pricing of Services:

Directing Clients to Capitalize on the Safe Harbor

Recording of a 100-minute CPE webinar with Q&A

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Conducted on Tuesday, May 8, 2007

Course Materials


Despite the IRS' position that companies improperly move income attributed to U.S. intangible assets off shore for tax purposes, the agency’s new temporary regulations on transfer pricing are positive for business.

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.

Accounting firms must prepare their clients’ tax counsel and in-house tax specialists to leverage this new advantage. Advisors should be well-versed in the new regs and poised to help shape companies’ transfer pricing strategies to take full advantage.

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.



You’ll leave the teleconference thoroughly briefed and fortified to help client companies:

  • 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 every group member.
  • Discover how to share services among related business entities when those services aren't eligible for the cost safe harbor.
  • Meet the IRS' revised documentation standards.


Brian Becker
Brian Becker
President and CEO
Precision Economics Inc.,

Precision Economics is a transfer pricing consulting practice, and Brian consults on transfer pricing issues for both...  |  Read More

Alan Granwell
Alan Granwell
DLA Piper

He’s been practicing in international taxation for more than 35 years and previously was director of the Treasury...  |  Read More

Valerie Amerkhail
Valerie Amerkhail
Director of Transfer Pricing Services
Economic Consulting Services

She consults with international tax attorneys on IRS field exams, advanced pricing agreements and documentation reports...  |  Read More

Patricia Lewis
Patricia Lewis
Caplin & Drysdale

She's been with the firm nearly continuously since 1971 and her practice focuses on international transfer pricing and...  |  Read More