IRS

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Multinational corporations are subject to transfer pricing regulations under Section 482 of the tax code that are intended to ensure that companies do business with their related foreign entities at “arm’s length,” and that taxes paid in each country are commensurate with the income the company realizes in that jurisdiction. The IRS issued new rules for cost sharing arrangements in December 2008, and companies now are faced with interpreting the new requirements to make sure they are reporting the correct proportion of their profits on their U.S. tax returns. Their decisions are particularly important considering a provision of the new rules that allows the IRS to invalidate a cost sharing arrangement if it doesn’t agree.

The Knowledge Congress is assembling a panel of distinguished professionals and key regulators to help companies understand the new regulations. The speakers will share their expert opinions in a two-hour LIVE Webcast.

Course Level: Intermediate
Prerequisite: None
Method Of Presentation: Group-Based-Internet
Developer: The Knowledge Conference
Recommended CLE/CPE Hours: 1.75 - 2.0
(Please note, your State Bar or Accounting Board will make the final determination with respect to continuing education credit. If you are applying for CLE credit in Texas you must register 20 days before the event date.)
Advance Preparation: Print and review course materials
Course Code: 093835
Recording Fee: $299 (Please click here for details)
NASBA Sponsor Number: 109004

 

Featured Speakers for Understanding New IRS Rules live webcast:


  Event Talking Points (click here to view more)
SEGMENT 1:


Alan Shapiro, Partner, Global Transfer Pricing,
Deloitte Tax LLP

- Temporary Cost Sharing Regulations
- Introduction – History
- Introduction – Now
    - Temporary Cost Sharing Regulations
- Introduction – Actions
    - Compliance with Temporary Cost Sharing Regulations

SEGMENT 2:


E. Miller Williams, Jr., Partner/Principal – National Transfer Pricing,
Ernst & Young LLP

- Major changes – the “New” PCT
- Major changes: Income method
- Major changes – Investor model

SEGMENT 3:


Jon Silverman, Ph.D., Principal, Global Transfer Pricing Services,
KPMG

- Discount Rates
    - 2005 Proposed Regulations
      - Investor Model
      - WACC, IRR
    - 2009 Temporary Regulations
      - Licensing vs Licensor
      - Pre versus post tax
    - Financial Statement Valuation approach
      - WARA
    - Commentary

- Periodic Trigger
    - 2005 Proposed Regulations
      - PRRR
      - AERR
    - Temporary Regulations
    - Periodic Trigger test
    - Calculations Steps from regulations
    - Exceptions to periodic adjustment
    - Reduced AERR and Example
    - Commentary

SEGMENT 4:


Alan Shapiro, Partner, Global Transfer Pricing,
Deloitte Tax LLP

- Major changes – Residual profit split
- Major changes – Acquisitions
- Major changes – IDCs
- Major changes - Tighter CWI regime
- Major changes – Other arrangements
- Transition rules and effective date



Deloitte Tax LLP
Alan Shapiro
Partner, Global Transfer Pricing
speaker bio »»

Ernst & Young LLP
E. Miller Williams, Jr.
Partner/Principal – National Transfer Pricing
speaker bio »»

KPMG
Jon Silverman
Ph.D., Principal, Global Transfer Pricing Services
speaker bio »»

KPMG
Kent Wisner
Principal, International Corporate Services, California
speaker bio »»

Who Should Attend?

- Multinational Companies
- Consultants
- Attorneys in Transfer Pricing Practices

Why Attend?

This is a must attend event to anyone interested in understanding the related updates on IRS Rules That Restrict Profits Sent Overseas
- New guidance explained by the most qualified key leaders & experts
- Hear directly from key regulators & thought leaders
- Interact directly with panel during Q&A

Registration Information:                                                                                                                                    



Understanding New IRS Rules That Restrict Profits Sent Overseas
Speaker Firms:









Media Partner:






 

The Knowledge Conference 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. Website: www.nasba.org

 

We are an approved multi-event sponsor in the state of California. Our provider ID is: 14451. In Texas, Illinois, and Virginia, we submit programs for individual approval in advance. In New York, our programs are submitted immediately after the event live date and attendees are sent the approval codes once we receive them from the New York State Bar. In all other states, once attendance is verified, participants are emailed an official certificate of attendance which they submit to their respective State Bar Associations. Our programs are created with continuing education in mind and are therefore designed to meet the requirements of all State Bar Associations. If you have any questions, please email our CLE coordinator at: info@knowledgecongress.org

 
Enrolled Agents Sponsor ID Number: 760

We have entered into an agreement with the Office of Professional Responsibility, Internal Revenue Service, to meet the requirements of 31 Code of Federal Regulations, section 10.6(g), covering maintenance of attendance records, retention of program outlines, qualifications of instructors, and length of class hours. This agreement does not constitute an endorsement by the Office of Professional Responsibility as to the quality of the program or its contribution to the professional competence of the enrolled individual.