Course/Product Description Title: Transfer Pricing - 2 Day Seminar Duration: 2 days Description: TThe IRS is stepping up enforcement on documentation to support transfer pricing strategies. As tax authorities are demanding more evidence, corporate taxpayers will need to demonstrate that prices charged for intercompany services and transactions are appropriate. This course will provide a detailed understanding of the model for analysis, comparability, Transfer Pricing methods, as well as, discuss the cost sharing and service regulations and explain advance pricing agreements. Please see the agenda below for more details. Agenda DAY ONE: 8:30 am Registration and Continental Breakfast 8:45 am Welcome and Chairs’ Opening Remarks 9:00 am Transfer Pricing: State of the “Art” Global Enforcement Recessionary Impact Business Restructuring Intangibles and Services Issues Transfer pricing and FIN 48 9:45 am Refreshment Break 10:00 am Working With the New Service Regulations Qualifying for the Services Cost Method Headquarters Costs Allocations The “Sole Effect” Test Stock Based Compensation Benefits of intercompany service agreements 11:15 am Adapting to the New Cost Sharing Regulations Cost Sharing Arrangements - Changing Landscape How will they impact your company’s foreign subsidiaries How do the taxing authorities evaluate cost sharing arrangements Payment disputes that arise in cost sharing arrangements Classifying intangibles 12:30 pm Luncheon 1:30 pm Treatment of Intangibles Defining and classifying intangibles Determination of intangibles from both a legal and an economic perspective Inter-company transfer of intangibles Valuation of intangibles Stock options 2:45 pm Transfer Pricing Differences in Other Countries Canada OECD Guidelines Other Countries Enforcement Efforts 4:00 pm Break 4:15 pm Transfer Pricing Documentation Current environment TP in a recession Defending historical positions Is routine really routine Audit and APA strategies Restructuring and planning opportunities 5:15 Seminar adjourns for the day DAY TWO: 8:30 am Continental Breakfast 9:00 am Recap and Overview 9:15 am Handling an IRS Transfer Pricing Examination Documentation requirements and coordination with other affected jurisdictions Types of information requests and response strategies Factors that will trigger an audit Defense strategies Responding to draft proposed adjustments 10:15 am Advanced Pricing Agreements/Competent Authority How and When to Consider an APA Unilateral vs Bilateral The APA Process When to use the competent authority process When to go for arbitration 11:15 am Break 11:30 am Transfer Pricing Planning The arm's length standard: is it being incrementally weakened? Restructuring in Europe: The OECD Discussion Draft IP tax planning and cost sharing post-Veritas 12:30 pm Conference Concludes Who Should Attend There is no advance preparation for this basic to intermediate level seminar. The course is transitional and non-transitional which is appropriate for new and experienced attorneys. This seminar is for corporate tax professionals such as VP Taxes, tax directors, tax specialists, senior tax managers, tax attorneys and in-house counsel. Prerequisite: You must have attended a basic level or introductory course on international tax. Continuing Education Credits Up to 13 CPE/CLE Credits CPE Credits: Networking Seminars Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the national Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. www.nasba.org CLE Credits: Continuing Legal Education Credits will be sought by those who request it at the seminar. Each state will have final approval on the exact number of credits granted. Transitional and/or non-transitional continuing legal education is available depending on the level of seminar. Accreditation is pending until approved by each CLE board. CLE is an important aspect of our seminars and we want to make sure you receive the appropriate accreditation. Accommodations Hotel Reservations are at your own discretion. We suggest these two hotels which are within a two minute walk to our conference room. Dallas: The Westin Galleria 13340 Dallas Parkway Dallas, Texas 75240 Phone: (972) 934-9494 Le Méridien Dallas North 13402 Noel Road Dallas, Texas 75240 Phone: (972) 503-8700 Cancellations/Substitutions All cancellations must be received 5 business days prior to seminar date to receive a refund less a $100 processing charge. You can send a substitute or you can also request a credit in full to attend another seminar. No refunds can be processed within 5 business days of the seminar. You would, at that point, receive a credit to attend another seminar. If you fail to attend or inform us of your cancellation, you will lose your opportunity to request a refund or credit for the seminar. About The Provider: Networking Seminars organizes educational seminars and unique networking events on cutting edge information for the tax, legal, finance and accounting industries. We bring together an international community of professionals and industry experts to learn the latest news and informaton, exchange ideas, share experiences and cultivate new business relationships. Networking Seminars Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the national Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be addressed to the National Registry of CPE Sponsors, 150 Fourth Avenue North, Suite 700, Nashville, TN 37219-2417. We also offer CLE course credits and file with each state by those requesting credit at the seminar. Price: $1,095.00 More Info: Contact Us For More Information

Keywords For This Course:
transfer pricing, dallas, texas seminars