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
This CLE/CPE course 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.
Outline
- The federal landscape of transfer pricing: Section 482; 26 CFR 1.482-1 through 9
- Global transfer pricing trends, new LB&I directives and increased scrutiny for U.S. multinational companies
- Determining taxpayer transfer pricing methods and intercompany arrangements
- IRS best methods evaluation, Section 6662(e) document production, and required transfer pricing review
- State transfer pricing authority and controversy considerations
- 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
Steven (Steve) Toscher
Managing Principal
Hochman Salkin Toscher Perez
Mr. Toscher has been representing clients for more than 35 years before the Internal Revenue Service, the Tax Divisions... | Read More
Mr. Toscher has been representing clients for more than 35 years before the Internal Revenue Service, the Tax Divisions of the U.S. Department of Justice and the Office of the United States Attorney, numerous state taxing authorities and in federal and state court litigation and appeals. Mr. Toscher enjoys a unique combination of solid criminal defense experience and extensive substantive tax experience to assist individuals and entities subject to sensitive government inquiries. He has considerable experience as lead counsel in defending criminal tax fraud investigations (both administrative and grand jury investigations) as well as in defending criminal tax prosecutions (both jury and non-jury). Mr. Toscher’s tax practice includes a wide array of substantive areas including income taxes, estate taxes, employment taxes, sales taxes and property taxes. He is routinely involved in sensitive issue or complex civil tax examinations and administrative appeals on behalf of wealthy individuals and their closely held entities as well as large corporations involving both domestic and foreign tax related issues.
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Lacey Strachan
Hochman Salkin Toscher & Perez
Ms. Strachan concentrates her practice in complex civil tax litigation and criminal tax prosecution, representing... | Read More
Ms. Strachan concentrates her practice in complex civil tax litigation and criminal tax prosecution, representing individuals, corporations, pass-through entities, trusts, and estates in all stages of state and federal tax disputes. She has been extremely successful in a wide range of sophisticated tax cases involving an array of substantive tax issues, including transfer pricing adjustments under section 482 for foreign related-party transactions, passive loss limitations for real estate investors, section 1031 transactions, bad debt deductions, deductibility of business expenses, substantiation of basis, characterization of shareholder loans, and accumulated earnings tax.
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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
Ms. Voth is a Managing Director at WTP Advisors with nearly 20 years experience in transfer pricing and valuation services. Prior to joining WTP, she was a Senior Manager in Deloitte’s transfer pricing practice. She has been providing valuation, transfer pricing, and economics consulting services to companies in a variety of industries since obtaining her Ph.D. in Applied Economics. While technology and pharmaceuticals are her primary industries of focus, she also has significant experience with retail, manufacturing, and consumer goods industries, among others.
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