Transfer Pricing & IRS Audits
Overview:Recently, there have been a lot of regulatory changes and stepped up enforcement efforts with respect to transfer pricing. Tax and accounting professionals must be continuously in-the-know about transfer pricing and audit updates to avoid penalties and fines.
The Knowledge Group has assembled a panel of experts to break down the complexities of this topic focusing on the US transfer pricing landscape as well as foreign audit environments. They will also discuss up-to-the-minute regulatory updates and the significant impact of transfer pricing rules and methods to companies in a LIVE, two-hour webcast.
The audience will have an opportunity to ask the speakers questions directly during the live Q&A session. Sign up for this class by clicking the “Register” button below. Advanced registration is recommended as space is limited and significant discounts apply to early registrants.
All Speaker's talking points:
1. Introduction - Current Environment on TP
2. Reorganization of LB&I with regards to transfer pricing
3. Documentation Rules and Penalties
4. Forms 5471 and 5472 and Similar Foreign Country Forms
5. IRS TP Audit Process
6. IRC 6038A and IRS Summons Authority
7. Instructions to Filed Agents - Tiered Issues
8. Commentary on IRS Audits
9. IRS Appeals
10. Income Tax Treaty - Define
11. What is CA, How it works, CA Statistics
12. Applications to TP Audit
13. Arbitration Clause and how it works
14. APA - What is on AP - Statistics, Benefits of APA, APA Process Current
15. How APA and CA work together
16. current issue on APA program
17. conclusion comments on APA and CA
Who Should Attend:
- Senior Corporate Executives
- Tax Directors
- Tax Managers
- Chief Financial Officers
- Multinational Companies
- Lawyers and Accountants specializing in Transfer Pricing
E. Miller Williams, Jr. is the SESA Transfer Pricing Controversy Leader. Mr. Williams consults with multinational corporate clients on a national basis regarding complex transfer pricing matters with an emphasis on international transfer pricing controversy, advanced pricing agreements (APA), competent authority, and intercompany planning and structuring.
Mr. Williams has over 19 years of transfer pricing consulting experience (5 with the government and 14 in private practice) with companies in a variety of industries. His industry experience includes work with paper and pulp, building products, pharmaceutical, semiconductors, software, packaging, retail, consumer products, motor vehicles, automotive parts, heavy equipment, and industrial machinery. Mr. Williams is a frequent speaker at Council for International Tax Education Seminars and other tax seminars and has authored a number of transfer pricing articles.
Prior to joining Ernst & Young, Mr. Williams headed the Southeast transfer pricing practices of a previous Big 5 Firm and of one of the current Big 4 Firms in Atlanta. Prior to private practice, Mr. Williams served as a Senior Attorney in the Office of Associate Chief Counsel (International) for the IRS in Washington D.C working on a variety of transfer pricing and international tax matters. As a member of that office, he worked in the APA Program where he acted as lead attorney on many APA cases and as advisor to the Director on APA procedures.
Mr. Williams received his LLM in Taxation from Emory University, his J.D. from Stetson University College of Law and his undergraduate degree from Vanderbilt University. Prior to working for the IRS, Mr. Williams served as an officer and attorney in the United States Army Judge Advocate General's Corps where he held positions as a prosecutor, defense attorney and administrative law attorney. He is a member of the Georgia Bar Association and the American Bar Association Tax Section, and is a board member and officer of the Georgia Council for International Visitors and board member of the Atlanta Area Council of the Boy Scouts of America.
E. Miller Williams, Jr. is the SESA Transfer Pricing Controversy Leader. Mr. Williams consults with multinational corporate clients on a …
Bob Cole is founding chair of the firm’s International Tax Group. He concentrates his practice on transfer pricing, tax treaties and other international tax issues for U.S. business operations abroad, foreign business operations in the United States and for U.S. investments of wealthy families.
In his transfer pricing practice, he assists multinationals in a variety of contexts, including the development and contractual implementation of worldwide transfer pricing systems, advising on transfer pricing issues in connection with mergers and acquisitions and spin-offs, advising on and implementing cost sharing arrangements, advising on the self-compliance and documentation process needed to avoid transfer pricing penalties in the United States and other countries, counseling with respect to U.S. and foreign tax audits, representation in domestic dispute resolution proceedings, representation in Competent Authority proceedings under tax treaties, representation in securing advance pricing agreements (APAs), and lobbying on regulations.
In addition to transfer pricing, Bob advises and provides representation on the full range of international tax issues, such as the allocation of expenses for foreign tax credit and U.S. trade or business purposes, structuring mergers and acquisitions, the tax effects of various site location decisions, other tax treaty issues, tax dispute resolution under domestic and Competent Authority procedures, securing rulings from the Internal Revenue Service, lobbying on various international tax issues involved in regulations in tax treaties and in legislation.
Mr. Cole has participated in hiring and training some of the best international tax lawyers in the country who continue to work closely with him at Alston & Bird in providing the best international tax advice and representation available. In addition, he has developed close working arrangements with tax professionals and tax officials in other countries, enabling him and his colleagues to provide seamless advice and representation on the foreign tax aspects, as well as the United States and treaty aspects of international tax issues.
Bob is the editor and principal author of Practical Guide to U.S. Transfer Pricing; a co-author of the Tax Management (BNA) Portfolio on “Income Tax Treaties – Administrative and Competent Authority Aspects” and is a frequent author and speaker in numerous U.S. cities and foreign countries. He is listed in The Best Lawyers in America, the 25th anniversary edition of The Best Lawyers in America in the specialty of tax law and Euromoney's Guide to the World’s Leading Transfer Pricing Advisers.
Mr. Cole served in the U.S. Treasury from 1967 to 1973 and was appointed as the first International Tax Counsel in 1971. He negotiated tax and other treaties for the United States, including those with Australia, Belgium, Japan, Korea and Switzerland; developed the U.S. Competent Authority procedure for resolving transfer pricing and other issues under tax treaties; led the development of the rules for the allocation of expenses in cross-border situations.
Mr. Cole received his LL.B., magna cum laude, in 1956 from Harvard Law School where he was an editor of the Harvard Law Review; his B.S. (Econ.) in 1953 from the Wharton School; and an Academic Postgraduate Diploma in Law in 1959 from the London School of Economics. He is a Fellow of the American College of Tax Counsel, a member of the Council of the USA Branch of the International Fiscal Association, a past vice-chair of the Tax Committee of the National Foreign Trade Council and a member of the Tax Section of the American Bar Association.
- Counsel on transfer pricing and related matters to leading company in its industry and in numerous IRS audit and appeals proceedings.
- Counsel to a variety of U.S. and foreign companies in planning for and securing APAs.
- Counsel in numerous Competent Authority proceedings involving the United States and some 20 foreign countries.
- "The IRS Issues Proposed Cost Sharing Regulations," Corporate Business Taxation Monthly, January 2006.
- Practical Guide to U.S. Transfer Pricing, Third Edition, updated annually, LexisNexis® Matthew Bender&tradeTM.
Bob Cole is founding chair of the firm’s International Tax Group. He concentrates his practice on transfer pricing, tax treaties …
Brian Andreoli is a Partner in the New York City offices of DLA Piper L.L.P. (US) and is part of the Tax Practice.
Brian has been a tax professional for more than 30 years, with experience in public accounting, corporate (both foreign and domestic corporations), and litigation. He is known as a frequent speaker on international tax issues and transfer pricing matters in the United States, the United Kingdom, and Canada, and has recently been listed in the 2008 Guide to the World's Leading Transfer Pricing Advisers. He handles APAs, Competent Authority and frequently handles state tax litigation. He also advises on documentation under FIN 48.
Brian Andreoli is a Partner in the New York City offices of DLA Piper L.L.P. (US) and is part of …
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