Transfer Pricing: What You Need to Know in 2014
Overview:The Knowledge Group has assembled a panel of key thought leaders to provide the audience with an in-depth analysis of Transfer Pricing in 2014.Key issues include that will be covered in this course are:
- Transfer Pricing in 2014: an overview
- Latest trends and developments
- Emerging issues and preventing potential pitfalls and regulatory errors
- Understanding major impacts of recent critical changes
- Compliance and best practices
- Up-to-minute regulatory updates, useful insights and a lot more!
Alston & Bird LLP
- The ongoing effects of the consolidation into the Advance Pricing and Mutual Agreement (“APMA”) program of the formerly separate APA program and those Competent Authority functions (including mutual agreement procedures) related to transfer pricing and other allocation issues. This would include a discussion of the recently proposed update to the existing guidance regarding the procedure for obtaining an APA (Rev. Proc. 2006-9) contained in Notice 2013-79.
- The recently proposed update to the existing guidance regarding the procedure for seeking competent authority relief (Rev. Proc. 2006-54) contained in Notice 2013-78.
- The status of the ongoing international project to combat base erosion and profit shifting (BEPS), with a focus on the impact that process might have in the US (e.g., increasing demand for double tax relief, US focus on inbound investment and protecting the tax base). This could be either paired with or discussed separately from the issue of international tax reform in the US (e.g., the Camp proposal).
- The status of high profile litigation involving transfer pricing, including Eaton (revocation of APAs), Amazon & Altera Corp. (cost sharing), etc.
Peters Advisors LLC
- Challenges and opportunities from the OECD’s Guidance on Transfer Pricing Documentation and Country-by-Country Reporting.
- What the OECD’s Guidance on Transfer Pricing Aspects of Intangibles means for IP planning, management, and valuation.
- The European Commission’s challenge of transfer pricing arrangements as illegal state aid.
Who Should Attend:
- Pricing Analysts
- Related Finance Executives
- Senior Financial Professionals
- Transfer Pricing Attorneys
- Transfer Pricing Practitioners
- Treasury Managers
- Tax Directors
- Tax Executive
- Tax Managers
- Senior Corporate Management
- Senior Counsel
- Senior Executives
- Senior Management
- Senior Management and Board Members
- Senior Managers
- Senior Officers
- Multinational Companies
- Multi-National Corporations
- And other Related/Interested Professionals
Matthew Moseley’s practice focuses on the U.S. federal income tax consequences of cross-border business transactions. Mr. Moseley has experience in international transfer pricing matters, including the transfer of intellectual property, structuring the acquisition or disposition of U.S. or foreign business entities, planning international reorganizations, and determining the applicability of U.S. tax treaties. He has prepared and negotiated cost-sharing agreements, assisted clients in obtaining advanced pricing agreements and guided clients through the process of seeking competent authority relief. He has advised clients regarding controversies during the audit process, on administrative appeal and through alternative dispute resolution proceedings.
Prior to focusing on tax matters, Mr. Moseley practiced in commercial litigation. Before attending law school, he worked as a mission control analyst for Lockheed-Martin.
Matthew Moseley’s practice focuses on the U.S. federal income tax consequences of cross-border business transactions. Mr. Moseley has experience in …
Kurt Wulfekuhler has advised a wide array of companies on transfer pricing since 1997. His clients include leading multinational firms in the pharmaceutical, medical-device, technology, and financial-services industries. Before joining Peters Advisors, he led the transfer pricing group of KPMG LLP in Philadelphia.
Kurt has provided a full range of transfer pricing services to his clients from planning to documentation to audit support. He has extensive experience in the valuation of intangible property and provision of intercompany services. He developed a national group at KPMG to provide activity-based costing services for head-office expense allocations and other purposes. He has led a number of global cost-allocation projects and intangible property planning projects.
Kurt received his AB in Mathematical Economics from Brown University and MS in Mathematics/Statistics & Operations Research from New York University.
Kurt Wulfekuhler has advised a wide array of companies on transfer pricing since 1997. His clients include leading multinational firms …
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About Alston & Bird LLP
Alston & Bird is a leading national AmLaw 50 firm with offices in Atlanta, Brussels, Charlotte, Dallas, Los Angeles, New York, Research Triangle, Silicon Valley and Washington, D.C. The firm's more than 800 attorneys provide a full range of services to domestic and international clients conducting business around the world. Alston & Bird has overlaid its broad range of legal skills and business knowledge with a commitment to innovation and technology. The firm’s core practice areas are intellectual property, complex litigation, corporate and tax, with national industry focuses that include financial services, technology, health care, manufacturing, life sciences and energy. The firm has built a reputation as one of the country’s best employers, appearing on FORTUNE magazine’s ranking of the “100 Best Companies to Work For” 15 consecutive years, an unprecedented accomplishment among law firms in the United States.
About Peters Advisors LLC
Peters Advisors LLC is an independent provider of transfer pricing and valuation services. The firm assists its clients in all aspects of transfer pricing including planning, implementation, compliance, and audit support. Peters Advisors also provides valuation services especially of intangible property and for tax purposes.