Transfer Pricing for Mid-Market Companies: New IRS Directives, Intercompany Agreements, Avoiding Risk and Penalties

Recording of a 110-minute CPE webinar with Q&A


Conducted on Thursday, May 31, 2018

Recorded event now available

or call 1-800-926-7926
Program Materials

This CLE/CPE webinar will guide tax counsel and professionals on managing transfer pricing issues post-tax reform for mid-market companies. The panel will discuss provisions of the new tax bill that impact transfer pricing, recent procedural changes and directives issued by the IRS Large Business and International (LB&I) division, and strategies for intercompany agreements and avoiding penalties and audits.

Description

Multi-jurisdictional companies typically operate through multiple corporate entities requiring intercompany transfer pricing arrangements, which the IRS, states and foreign governments scrutinize. The IRS has the authority to review the transfer pricing methods of business entities generating foreign income and make adjustments under IRC §482, which typically results in a significant tax liability assessment.

The LB&I recently released several directives geared toward transfer pricing issues. These directives focus on the application of IRC §6662(e) penalties, correctly identifying transfer pricing issues, and transfer pricing approaches for businesses based on a best methods analysis. Understanding these directives and the examination process of the LB&I will assist tax advisers in developing intercompany arrangements and avoid audits or penalties.

Also, many states challenge intercompany transactions through statutes and regulations similar to IRC §482 to collect additional revenue. States that have not adopted IRC §482 or similar rules may also negate the effect of intercompany transactions through discretionary powers to adjust income, statutes requiring the addback of some intercompany payments, or the assertion of nexus principles for entities not physically present in the state.

Listen as our panel provides guidance on the laws and regulations affecting transfer pricing, methods to establish compliant intercompany arrangements, and techniques to manage transfer pricing challenges and penalties.

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Outline

  1. The federal landscape of transfer pricing: Section 482; 26 CFR 1.482-1 through 9
  2. Global transfer pricing trends, new LB&I directives and increased scrutiny for U.S. multinational companies
  3. Determining taxpayer transfer pricing methods and intercompany arrangements
  4. IRS best methods evaluation, Section 6662(e) document production, and required transfer pricing review
  5. State transfer pricing authority and controversy considerations
  6. Best practices for transfer pricing methods, intercompany arrangements and avoiding penalties

Benefits

The panel will review these and other crucial issues:

  • Transactions subject to transfer pricing rules
  • Defining “related parties” for transfer pricing purposes
  • Procedures governing the preparation and filing of transfer pricing documentation
  • Standards and procedures that govern a tax authorities’ review of companies’ compliance with transfer pricing rules
  • Assessment of penalties for noncompliance with transfer pricing rules
  • Challenging adjustment decisions by tax authorities

Faculty

Toscher, Steven
Steven Toscher

Principal
Hochman Salkin Rettig Toscher & Perez

Mr. Toscher has been representing clients for more than 35 years before the IRS, the Tax Divisions of the U.S....  |  Read More

Strachan, Lacey
Lacey Strachan

Hochman Salkin Rettig Toscher & Perez

Ms. Strachan concentrates her practice in complex civil tax litigation and criminal tax prosecution, representing...  |  Read More

Voth, Nancy
Nancy Voth
Managing Director
WTP Advisors

Ms. Voth is a Managing Director at WTP Advisors with nearly 20 years experience in transfer pricing and valuation...  |  Read More

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