Transfer Pricing for Worldwide Income: New Rules and Enforcement

Transfer Pricing New Rules and Enforcement

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

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford CPE+ Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Tuesday, April 10, 2012

Recorded event now available

or call 1-800-926-7926
Course Materials

This teleconference will provide tax counsel with a review of U.S. rules on transfer pricing, provide guidance on efficiently resolving Advance Pricing Agreement issues at the reorganized IRS, and evaluate the new cost-sharing regulations.


The IRS has the authority to adjust deductions or credits to business entities generating foreign income under the tax code's provisions on transfer pricing. Businesses manage the uncertainty of transfer pricing taxes by undertaking the long and arduous process of Advance Pricing Agreements.

The Service responded to calls for increased efficiency and staffing, and expanded its international programs through consolidation.

However, the IRS is introducing more than just structural change. New transfer pricing rules are also being introduced, with the recent release of cost-sharing regulations affecting companies that enter into agreements to share the price of intangible goods or services.

Listen as our authoritative panel of experienced transfer pricing professionals examines the most recent changes to transfer pricing rules and IRS enforcement, offers best practices for resolving Advance Pricing Agreement disputes, and analyzes the new cost-sharing regulations.



  1. Transfer Pricing Practice
  2. The IRS Advance Pricing Agreement Program
  3. Process changes from IRS restructuring
  4. Cost-sharing regulations


The panel will review these and other key questions:

  • What does tax counsel need to know about transfer pricing adjustments under the U.S. tax code?
  • What steps should counsel take to enter Advance Pricing Agreements and avoid delays under the restructured IRS?
  • What are the new rules impacting cost-sharing?

Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.


Valerie Amerkhail
Valerie Amerkhail

Director, Transfer Pricing
Economic Consulting Services

She has worked closely on transfer pricing issues with international tax attorneys from many of the leading U.S. law...  |  Read More

Brian Becker
Brian Becker

Precision Economics

Since completing his Ph.D. from the Wharton School, he has focused on transfer pricing, valuation, damage calculations...  |  Read More

Jerrie Varrone Mirga
Jerrie Varrone Mirga

Vice President
Economic Consulting Services

She is an economist and works with clients in a wide range of industries, predominantly in the areas of international...  |  Read More

Neal M. Kochman
Neal M. Kochman

Caplin & Drysdale

His practice focuses on international tax planning, taxation of settlements, and bankruptcy tax matters with experience...  |  Read More

Access Anytime, Anywhere

Strafford will process CLE credit for one person on each recording. CPE credit is not available on recordings. All formats include course handouts.

To find out which recorded format will provide the best CLE option, select your state:

CLE On-Demand Audio