Key Issues in
Global Transfer Pricing
Get Latest Regulatory Updates and Practical Guidance for Successful Audit Defense
September 28 and 29, 2010
Optional Workshops: September 30, 2010
Congress Plaza Hotel
CHICAGO, ILLINOIS
Conference Program Agenda - Day Two
Wednesday, September 29, 2010
| 8:00 - 8:30 |
Continental Breakfast |
8:00 - 8:30 |
8:30 - 8:40
Opening Remarks from the Chair
Russell Young, Partner, Baker & McKenzie LLP
8:40 - 9:40
Discussion of the Economic Analysis in a Challenging Economic Environment
Theodor van Stephoudt, Principal Economist, DLA Piper LLP
- Overview of economic analysis
- Issues created by a challenging economic environment
- Arguments of the tax authorities
- Recent experiences
- Summary, conclusion, and lessons learned
9:40 - 10:30
How to Prepare Effective Documentation
Deloris Wright, President, Wright Economics Inc.
- Approaches to documentation
- Functional analysis: making it useful
- Industry analysis: what is the purpose; how do you do it
- Economic analysis: approaches to comparables searches
- Intercompany agreements and other types of documentation
| 10:30 - 10:40 |
Networking Break |
10:30 - 10:40 |
10:40 - 11:40
Hot Audit Issues for Today and Tomorrow: Key Insights on Effective Strategies
Andrew Sliwa, Managing Director, Ceteris
Christopher Desmond, Ceteris
- Current issues from a financial audit perspective
- Current issues from an IRS audit perspective
- Financial audits: effective strategies for dealing with your auditor
- Tax audits: building your best transfer pricing position for the IRS and other taxing authorities
- Procedural strategies and considerations
11:40 - 12:30
Supply-Chain Management Issues
Kathrine Kimball, Vice-President, Charles River Associates
Bob Alltop, Vice President Global Leader Transfer Pricing, Charles River Associates
Richard Timmel, Partner, Mayer Brown
- Overview and issues with traditional supply-chain models
- Integrating tax planning into and key tax issues with supply-chain management
- Impact of OECD Discussion Draft on Business Restructuring
| 12:30 - 1:30 |
Luncheon Break |
12:30 - 1:030 |
1:30 - 3:00
Panel Discussion
Specific Industry Challenges in Transfer Pricing and Best Practices in Dealing with Them
Harry Keates, Vice-President, Wright Economics, Inc.
Barry Agranoff, International Tax Manager, Pearson Inc.
Kelly Russell Turner, Senior Director, Transfer Pricing, Electronic Arts Inc.
Joshua Wookey, Director, Transfer Pricing, Oracle
- Industry experts discuss specific transfer pricing challenges at their companies
- Unique aspects and real-world applications of transfer pricing
- Practical examination of different approaches to transfer pricing
- Predictions for the future of transfer pricing
| 3:00 - 3:20 |
Networking Break |
3:00 - 3:20 |
3:20 - 4:10
Transfer Pricing and Customs Valuation: What You Need to Know (What You Don't Know Can Hurt You)
Damon Pike, President, The Pike Law Firm, P.C.
Dalton Albrecht, Partner, International Trade Law and Commodity Tax, Miller Thomson LLP
- What is customs transfer pricing?
- Why is it different than income tax and transfer pricing? What are the similarities?
- New issues and developments: recent rulings, compensating adjustments, management fees, and subsequent proceeds
- Canada-U.S. comparative trends
- Penalties
- Enforcement priorities
- Real-life case study
4:10 - 5:00
Practical Lessons Learned from Transfer Pricing Legal Cases
Marc Levey, Partner, Baker & McKenzie LLP
- GlaxoSmithKline and DHL: the world of marketing intangibles and what it means to you
- Xilinx and Vertias: what is happening with cost sharing?
- Container Corporation of Canada and guarantee fees
- Zimmer SAS and commissionaires
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