State Transfer Pricing Audits: Forced Combinations, Add-Backs, IRC Section 482, and Recent Cases
Recording of a 110-minute CPE webinar with Q&A
This course will discuss the rise in state challenges of transfer pricing arrangements. Our panel of SALT veterans will cover choosing, documenting, and defending intercompany pricing agreements for multistate businesses.
Outline
- State transfer pricing overview
- IRC Section 482
- Pricing studies
- State-specific methods
- Transfer pricing enforcement
- Defending transfer pricing arrangements
- Best practices
Benefits
The panel will review these and other critical issues:
- Selecting appropriate transfer pricing methods
- Documenting pricing arrangements
- How specific states are challenging transfer pricing arrangements
- Implementing the best method for pricing arrangements
- How states incorporate the rules under IRC Section 482
Faculty

Davinia Lyon, CPA
Partner
TaxOps
Ms. Lyon specializes in corporate and international tax and planning, including income tax provisions (ASC 740),... | Read More
Ms. Lyon specializes in corporate and international tax and planning, including income tax provisions (ASC 740), business strategy tax impact analysis, transfer pricing, foreign compliance and reporting, M&A transaction and entity restructuring. She also counsels clients under audit and in their efforts to develop corporate tax departments and related support areas.
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Stacey L. Roberts, CPA
State and Local Tax Director
TaxOps
Ms. Roberts has been making SALT less taxing for thousands of businesses over the last 25 years. As a director of the... | Read More
Ms. Roberts has been making SALT less taxing for thousands of businesses over the last 25 years. As a director of the SALTovation team at TaxOps, she is at the table-and in the weeds-helping guide dynamic businesses through compliance and strategic planning that minimizes risk and strengthens tax positions. She entered accounting with Andersen Worldwide/Andersen LLP, where she honed her state and local tax experience. She added stints at KPMG and Deloitte before moving in-house with a Fortune 500 company, managing State and Local Tax Administration. Before joining TaxOps, she led the national SALT practice at a regional firm. Stacey is a member of the Colorado Legislative Task Force Concerning Tax Policy and a frequent speaker and author on SALT issues for industry and professional organizations, including the Journal of State Taxation, Strafford Publishing, and more.
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