Transfer Pricing: Crucial Strategies
Transfer pricing has become a big challenge to companies who are conducting operations in different countries in which their subsidiaries transact business with each other. Without proper documentation that would justify an arm’s length price of transactions, double taxation, imposition of stiff penalties and significant losses might result. The entities that are most impacted by this kind of challenge are the smaller companies, as compared to multinational companies. What kind of strategies should these companies execute in order to avoid the adverse effects of transfer pricing? The Knowledge Congress is assembling a panel of distinguished speakers to talk about effective strategies on how to handle this kind of challenge. Key regulators and experts in the field of finance and taxation are scheduled to speak in a two-hour webinar.
SEGMENT 1: J. Matthew Lowe, Senior Analyst, NERA Economic Consulting - Strategies for complying with the new IRS Temporary Service Regulations - Will the Income Method described in the Coordinated Issue Paper 482 CSA Buy-In Adjustments (Tier 1 issue) become the preferred method? SEGMENT 2: Jake Feldman, Ph.D., Executive Director, Transfer Pricing, Grant Thornton LLP - Stock option costs - More likely than not - Transfer Pricing litigation - Business reorganization and function shifting SEGMENT 3: Steven C. Wrappe, Principal, International Tax Services, Washington, DC, Ernst & Young LLP - Changes to intangibles ownership and implications of enhancement of non-owned intangibles - Procedural opportunities to resolve tax disputes regarding changed stewardship approach SEGMENT 4: Brian Andreoli, Partner, DLA Piper US LLP ** Speaker Agenda to be added soon.. **
Who Should Attend:
- Senior Corporate Executives - Tax Directors - Tax Managers - Controllers - Treasurers - Chief Financial Officers - Lawyers and Accountants specializing in Transfer Pricing
Jake is Executive Director - Transfer Pricing in the International Tax practice of Grant Thornton LLP where he is responsible for the delivery of a full range of international transfer pricing and tax services to clients in a wide variety of industries.
With 30 years tax and finance experience, Jake has conducted projects and traveled to over 40 countries in Asia/Pacific, Europe/Middle East/Africa and Latin America. His broad areas of expertise include US and foreign transfer pricing, cross-border tax planning, intellectual property planning, strategic financial analysis, tax-effective supply chain management, contract manufacturing, international treasury and foreign exchange management, joint ventures, acquisitions, divestitures, licensing and financial analytic methods.
Previously, Jake was Senior Director of International Tax Planning at Merck & Co., Inc. and Senior Director of its Global Entity Management department where he was head of its global transfer pricing function. Jake led Merck’s development and implementation of both its Asia Pacific and Latin America supply chain hub structures. He has also held a wide variety of positions in international treasury, financial analysis and international controllership.
Jake taught several years at New York University Stern School of Business as an Adjunct Assistant Professor of Finance. He has made presentations at national conferences sponsored by the Economist, Executive Enterprise Institute and Baker & McKenzie on tax subjects, restructuring activities and hedging strategies. Jake has been on the Editorial Advisory Board for publications covering business and finance in emerging markets for WorldTrade Executive and the Economist Intelligence Unit.
Professional qualifications and memberships
- International Fiscal Association - Member
- American Bar Association, Section of Taxation - Associate
- Executive Enterprise Institute - Faculty Member
- Financial Management Association - Member
- New York University Stern School of Business, Ph.D. in Finance and Operations Research
- City College of New York, B.S. in Physics and Mathematics, summa cum laude
Jake is Executive Director – Transfer Pricing in the International Tax practice of Grant Thornton LLP where he is responsible …
Steve is a principal in Ernst & Young’s Washington, DC Transfer Pricing practice. He brings over 25 years of tax experience, including over 15 years of specialization in all aspects of transfer pricing. Steve's experience in transfer pricing controversy includes: examination, appeals, ADR solutions, advance pricing agreements (APA), mutual agreement procedures (MAP), and Customs agreements. Steve’s combined APA/MAP experience includes in excess of 100 cases.
For the past year Steve has been a partner at a global law firm, and prior to that spent 10 years as a partner and Director of the APA practice at Deloitte Tax. Steve also brings a wealth of government experience to Ernst & Young, having served as an attorney at the IRS Office of Associate Chief Counsel (International) Advance Pricing Agreement Program.
Steve is actively involved in the international tax and transfer pricing community. Steve recently served as Chair of the Transfer Pricing Committee of the American Bar Association’s Tax Section. He serves on the Board of Advisors of the NYU School of Law - International Tax Program and BNA Tax Management (Transfer Pricing). Steve is an Adjunct Professor (Transfer Pricing) at Georgetown University Law Center, has published two books and numerous articles on transfer pricing topics, and speaks globally on transfer pricing and dispute resolution.
Steve is a principal in Ernst & Young’s Washington, DC Transfer Pricing practice. He brings over 25 years of tax …
Brian E. Andreoli focuses his practice on transfer pricing, international tax matters, and state tax matters. Mr. Andreoli has been a tax professional for more than 30 years, with experience in public, accounting, corporate (both foreign and domestic) law, and litigation. He has tried cases and administrative hearings in the states of New York, Connecticut, Ohio, California, Virginia, North Carolina, South Carolina, Pennsylvania and Washington. These cases have concerned corporate income tax, sales and use tax, franchise tax and property tax. He also practices in voluntary disclosures for both corporations and individuals, concerning both civil and criminal penalties.
Mr. Andreoli is admitted before the bars in Connecticut, New York, Massachusetts, and the District of Columbia, and is a Certified Public Accountant. He is licensed to practice in the United States Tax Court, Second Circuit Court of Appeals, the United States Supreme Court, and the Federal District Courts of the District of Columbia, Connecticut, Massachusetts, and New York (Southern and Eastern). He has been listed in the 2008 Guide to the World's Leading Transfer Pricing Advisers.
Education: J.D., Fordham University School of Law 1980; LL.M., Quinnipiac University School of Law 1988; M.B.A., New York University Graduate School of Business Administration 1975 and B.A., Franklin and Marshall College 1973.
Brian E. Andreoli focuses his practice on transfer pricing, international tax matters, and state tax matters. Mr. Andreoli has been …
J. Matthew Lowe is an economist in the Transfer Pricing Practice at NERA Economic Consulting in Washington, DC. He has co-authored numerous valuation studies for tax, litigation, and business planning purposes. He has extensive experience in valuing tangible and intangible property for transfer pricing studies across a variety of industries including pharmaceuticals, agricultural chemicals, and automobiles. In his transfer pricing work, he has used accounting, financial, statistical, and econometric analyses to identify arm’s-length prices consistent with U.S. and foreign tax guidelines. Mr. Lowe appeared before the APA Group at the Internal Revenue Service to discuss statistical models he prepared for a client to value intangible property. He co-authored the article "Patent Wars and Authorised Generics in the USA: Assessing the Issues" (with R. Rozek and E. Radel) published in Healthy IPRs: A Forward Look at Pharmaceutical Intellectual Property (M. Pugatch and A. Jensen, editors). He has also conducted statistical and econometric analyses for litigation matters ranging from damage calculations for alleged breach of contract disputes to evaluating market/commercial success for products embodying intangible property whose patents are challenged for invalidity. His litigation experience spans many industries including computer software, cosmetics, and pharmaceuticals. He received B.S. degrees (magna cum laude) in Business Management and Economics from Mary Washington College. Mr. Lowe earned his M.A. in Applied Economics from The Johns Hopkins University.
J. Matthew Lowe is an economist in the Transfer Pricing Practice at NERA Economic Consulting in Washington, DC. He has …
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