2019 Transfer Pricing Regulation Landscape: Heightened Enforcement Action and Compliance Practices
After the controversial Tax Cuts and Jobs Act (TCJA) created a remarkable impact to the transfer pricing landscape, transfer pricing has remained to be the most significant driver for the risks, challenges and financial complexities faced by multinational entities. The uncertainty brought by the ever-evolving economy for the past years has created an avenue for the noteworthy trends and developments to continuously reshape and modify the transfer pricing regulation landscape. Thus, potentially giving rise to more complex set of risks and pitfalls.
In order to succeed in this new and riskier transfer pricing environment and to avoid potential risks and pitfalls, it is important to have a complete understanding of the recent legal framework of the Transfer Pricing Regulation, the developments and trends surrounding this significant topic, and the possible implications it may create.
Listen as a panel of thought leaders and professionals provide the audience with a better understanding of the basic and most significant principles of transfer pricing. They will highlight the recent trends and developments surrounding this noteworthy topic. Speakers will also go beyond the basics and present key strategies and practical tips to avoid potential risks and pitfalls.
Key topics include:
- Transfer Pricing Regulation in the 2019 Landscape: An Overview
- Changes to Transfer Pricing Arrangements and Documentation
- The Amended Revenue Code: An Introduction
- Identifying Red Flags
- Risks, Challenges and Pitfalls
- What to Expect in 2019
HOCHMAN SALKIN TOSCHER PEREZ P.C.
- Overview of transfer pricing and the arm’s length standard.
- Recent updates in transfer pricing cases and IRS examinations.
- Potential penalties that may to apply and how to avoid them.
Valentiam Group LLC
Valentiam Group LLC
- Transfer pricing regulations are constantly changing on a global and national level, and risks are developing in regions previously considered to be relatively “safe”.
- The US’s own tax reform changes have made this environment even more complex from a US taxpayer perspective, and because US taxpayers cannot predict how other nations will respond to the US reforms.
- The best defense in this environment is ensuring that your company’s transfer pricing policies, strategies and pricing are consistent, thoughtful and well documented globally.
- For many companies, this may be achieved by having a control or collaboration center that oversees and communicates with the company’s value chain entities regarding consistent transfer pricing strategies, goals and deadlines.
Who Should Attend:
- Transfer Pricing Attorneys
- Transfer Pricing
- International Tax Consultants
- Chief Financial Executives
- Financial Management Officers
- Tax Professionals
- Taxation Lawyers
- Multinational Corporations
Lacey Strachan is a Principal at the law firm of Hochman Salkin Toscher Perez, P.C. and represents clients throughout the United States and elsewhere in complex civil tax litigation and criminal tax prosecutions (jury and non-jury). Ms. Strachan represents individuals and entities in litigation before both federal and state courts, including the federal district courts, the U.S. Tax Court, the U.S. Court of Federal Claims, and the Ninth Circuit Court of Appeals. Ms. Strachan has experience in a wide range of civil and criminal tax cases, including cases involving technical valuation issues, issues of first impression, and sensitive examinations where substantial civil penalty issues or possible assertions of fraudulent conduct may arise.
Lacey Strachan is a Principal at the law firm of Hochman Salkin Toscher Perez, P.C. and represents clients throughout the …
Mark is a partner in Valentiam Group and brings more than twenty years of transfer pricing experience having worked in both consulting and in-house transfer pricing roles at Ernst & Young, KPMG, Duff & Phelps and Procter & Gamble Corporation. Mark has advised companies across a spectrum of industries – including technology, consumer products, direct marketing, healthcare and professional services. Mark has also been recognized by Euromoney as one of the leading transfer pricing economists in North America.
Mark advises multinational companies on a wide range of transfer pricing and valuation issues, including the following: Global transfer pricing documentation in more than 40 countries; global transfer pricing planning; tax-efficient supply chain planning; intangible property valuations within the context of IRC §§ 482 and 367(d); operational transfer pricing, including ERP system integration; cost-sharing; Advance Pricing Agreements (APAs); audit defense; Competent Authority matters in North America, Asia and Europe; and, FIN 48 / ASC 740 compliance.
Mark is a partner in Valentiam Group and brings more than twenty years of transfer pricing experience having worked in …
Nancy is a Managing Director at WTP Advisors with over 15 years experience in transfer pricing and valuation services. Prior to joining WTP, Nancy was a Senior Manager in Deloitte’s transfer pricing practice. Nancy 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. Nancy’s expertise includes: identifying areas of transfer pricing risk in existing and proposed transactions and developing potential solutions to mitigate risk; determining implications of business model changes, including those occurring through merger and acquisition; performing intangible property analyses and developing financial valuation models; providing US and non-US audit support; overseeing transfer pricing documentation preparation; and supporting clients’ Advance Pricing Agreement applications and renewals. Earlier in her career, Nancy was an economic consultant performing valuation analyses for purposes of commercial litigation.
Nancy is a Managing Director at WTP Advisors with over 15 years experience in transfer pricing and valuation services. Prior …
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Method of Presentation:
General knowledge on transfer pricing
NY Category of CLE Credit:
Areas of Professional Practice
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About HOCHMAN SALKIN TOSCHER PEREZ P.C.
Hochman Salkin Toscher Perez, P.C. is recognized as the preeminent tax law firm on the West Coast. The firm specializes in civil and criminal tax litigation, tax controversies and tax disputes with the federal, state, and local taxing authorities; white collar criminal defense; estate planning and probate; and structuring and negotiating complex real estate, business, and corporate transactional matters. The firm maintains an active tax litigation practice and has received many notable decisions on behalf of its clients before the Federal Appellate Courts, the Federal District Courts, the Bankruptcy Courts, the United States Tax Court, and various state courts.
About Valentiam Group LLC
Valentiam Group is an innovative boutique professional services firm with locations across the US. Our name originates from the Latin phrase "ad valentiam" meaning "to the value.” Our team is comprised of professionals with extensive experience and educational experiences. We focus primarily on helping tax advisors determine an arm’s-length price of intercompany sales transactions and the fair market value of assets for federal, state, and local tax purposes. Our work entails both domestic and cross-border transactions.