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Course ID: 22278 | Course Duration: 1 Day | CEUs: CPE/CLE
 
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U.S. International Transfer Pricing 101 Training Class

Course ID: 22278
 
 
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U.S. International Transfer Pricing 101 Training Seminar

Transfer pricing in the United States continues to be a topic of major concern to tax executives at U.S. outbound and inbound multinationals. In today's environment of increased accountability, corporate executives must understand global pricing policies and transfer pricing risks and exposures before certifying tax return results.

Transfer pricing requires financial statement results to properly reflect profits between business units for tax and earnings forecasts. As a result, corporate tax and financial executives must establish effective internal controls and defend their pricing policies before their auditors and the IRS. Under FIN 48, Tax Departments will be required to measure and recognize potential transfer pricing exposure on a global basis.

Learn from our experienced staff of tax professionals, as we introduce tax practitioners to the key reporting and compliance issues under Section 482.


Benefits of Attending
  • Learn how the U.S. transfer pricing regime applies to related party sales and purchases of products by U.S. companies in the current economic environment
  • Find out how the IRS determines the amount of tax and penalties due on transactions with related parties, including conduit entities
  • Obtain the latest information on when U.S. tax adjustments may be required for intercompany service arrangements
  • Determine if your company/client benefits under the current Cost-Sharing regs. or should retain its current licensing arrangements
  • Receive an update on the latest IRS tools for resolving pricing controversies, including APAs, mediation, early referral and accelerated issue resolution
  • Increase your knowledge of how transfer pricing influences your company's financial statement results after Sarbanes-Oxley under FIN 48
  • Discover how to prepare a Transfer Pricing Study under the Sec. 482 regulations

Who Should Attend

This course is designed as a basic level introductory session for corporate tax executives and tax advisors from law and accounting firms. No prerequisites are required, although some knowledge of the U.S. international tax rules is recommended.


Schedule

Day One
8:00am - Registration and Continental Breakfast
9:00am - Overview of the U.S. Transfer Pricing Regime Under Sec. 482
10:15am - Break for Refreshments
10:30am - Establishing an Arm's-Length Price for Sales and Leases
12:15pm - LUNCHEON
1:30pm - Arranging for Intercompany Transfers of Intangible Property
3:15pm - Break for Refreshments
3:30pm - Managing the Corporate Transfer Pricing Function
5:00pm - Meeting Adjourns for the Day

Day 2
8:00am - Continental Breakfast
8:45am - Preparing a Transfer Pricing Study
10:00am - Break for Refreshments
10:15am - Understanding the New IRS Rules for Intercompany Services
11:30am - The Role of Transfer Pricing in Managing Your Global Effective Tax Rate
12:30pm - LUNCHEON
1:30pm - Resolving IRS Transfer Pricing Controversies
2:45pm - Break for Refreshments
3:00pm - Transfer Pricing Audit Administration and Procedure
4:30pm - Meeting Ends


Educational Course Credit

16 CPE/CLE Credits

CITE is registered with the National Association of the State Boards of Accountancy 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.

Complaints regarding registered sponsors may be addressed to NASBA, 150 Fourth Avenue North, Suite 700, Nashville, TN 37219-2417. CITE has been certified by the New York State Continuing Legal Education Board as an Accredited Provider of continuing legal education in the state of New York for the period of August 27, 1999 - August 27, 2002.

Continuing Education certificates will be distributed at the end of each meeting. This certificate must be retained.


Your Tuition Fee Includes

Continental breakfasts; lunches; refreshment breaks; calculator and documentation binder.


Accommodations

A limited block of rooms at a reduced rate has been set aside for attendees of our conferences. Please contact the appropriate hotel and mention that you are attending the conference listed under the Council for International Tax Education (CITE) in order to receive the discounted rate. Sleeping rooms are available on a very limited basis. We cannot guarantee rates or availability. Your sleeping room is not included in your registration fee.

Substitutions/Cancellations

Cancellations received more than 72 business hours prior to the meeting will be issued a credit. A $350 fee will apply to cancellations received within 72 business hours of the event. Credits will not be issued for "no shows". No credit card or cash refunds will be issued at any time.
 
     
     
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