Understanding New IRS Rules That Restrict Profits Sent Overseas

Summary:

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: 2.0
(Please note, your State Bar or Accounting Board will make the final determination with respect to continuing education credit.)
Advance Preparation: Print and review course materials
Course Code: 093835

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

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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

Understanding New IRS Rules That Restrict Profits Sent Overseas
LIVE Webcast

Thursday, June 18, 2009
3:00pm to 5:00pm (ET)