Latest Developments in
Global Transfer Pricing
Understanding the "Nuts and Bolts" of Transfer Pricing
October 17 and 18, 2011
Optional Workshops: October 19, 2011
Kingsmill Resort · Williamsburg, VA
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Conference Program Agenda - Day Two
Tuesday, October 18, 2011
| 8:00 - 8:45 |
Continental Breakfast |
8:00 - 8:45 |
8:45 - 9:00
Opening Remarks from the Chair
Brian Sturtz, Director, International Tax and Transfer Pricing, Walmart
9:00 - 10:00
Understanding Guarantee Fees
Brad Rolph, Vice-President, Charles River Associates
- In-depth examination and discussion of guarantee fees
- What are they? Why are they important? How to analyze them?
- GE Capital case: guarantee fees, transfer pricing, the arm's length principle and implications for pricing guarantee fees
- Top lessons learned from the case
 Brad Rolph has been advising multinational companies on a variety of transfer pricing issues for more than 15 years. His practice is focused on audit dispute resolution: giving expert witness testimony, providing litigation support, negotiating advance pricing arrangements, and submitting representations to the Transfer Pricing Review Committee, competent authority, appeals, and field auditors. Before joining Charles River to lead the Canadian Transfer Pricing Practice, Mr. Rolph was a partner and the chief economist of the National Transfer Pricing Group at Deloitte in Canada.
| 10:00 - 10:20 |
Networking Break |
10:00 - 10:20 |
10:20 - 12:00
Panel Discussion and Q&A
In-House Transfer Pricing: Practical Solutions to Audits and Common Issues
MODERATOR: Klaus Oehring, National Director, Transfer Pricing, UHY Advisors TX, LLC
Stanley G. Sherwood, International Tax Counsel, PPR /Gucci Group
Brian Sturtz, Director, International Tax and Transfer Pricing, Walmart
- 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
- Effective audit defense strategies
- Current audit situations with various countries
- Data collection: how to efficiently gather and analyze data
- Best practices in transfer pricing implementation
| 12:00 - 1:00 |
Luncheon Break |
12:00 - 1:00 |
1:00 - 2:00
International Tax Consequences of the Pricing of Intercompany Transactions
Brian Sturtz, Director, International Tax and Transfer Pricing, Walmart
Will James, Principal, Transfer Pricing, BKD LLP
- International tax impacts that arise as a consequence of transfer pricing
- Sourcing and foreign tax credit impacts from various common intercompany transactions
- Indirect tax and withholding tax ramifications that arise on intercompany service and IP transactions
- How slight modifications to the intercompany relationship can change the indirect tax and withholding tax costs of these transactions
- Creditable tax problems arising out of branch transactions
- Recent changes to transfer pricing rules that impact a company's international tax strategy in subtle, but important ways
- Subpart F and its relationship to transfer pricing
2:00 - 3:00
Transfer Pricing Updates and Challenges in Asia
Stanley G. Sherwood, International Tax Counsel, PPR/Gucci Group
- Documentation in Asia: Is it any different?
- Negotiating advance pricing agreements (APAs) with Asia-Pacific countries
- Finding comparables when there are none
- Use of secret comparables
- Mutual agreement procedure MAP cases
- Examples on the history of audits
 Stanley Sherwoodis an attorney and a former International Tax and Transfer Pricing Partner at PricewaterhouseCoopers in New York. He is currently responsible for transfer pricing planning, documentation, audit defense, MAP cases and APAs, and he is involved in all other aspects of global corporation taxation. Mr. Sherwood is independently rated in Euromoney's Guide to the World's Leading Transfer Pricing Advisers and in the Guide to the World's Leading Tax Advisers. He has served as an expert witness in tax cases involving transfer pricing and has been an advisor to the Chinese State Administration of Taxation in Beijing.
| 3:00 - 3:20 |
Networking Break |
3:00 - 3:20 |
3:20 - 4:00
Transfer Pricing in Europe: Key Issues and Updates
Klaus Oehring, National Director, Transfer Pricing, UHY Advisors TX, LLC
- Current European transfer pricing developments
- Simplification measures in transfer pricing rules
- Documentation requirements and information on penalties
- German restructuring regulations
- Examples of real-life audits and structures with countries in Europe
 Klaus Oehring practices in all areas of U.S. income taxation with special emphasis on international tax, transfer pricing and related tax accounting matters including FIN 48 and FAS 109. He has extensive experience preparing U.S. and foreign contemporaneous transfer pricing documentation and handling advanced pricing agreements, competent authority and tax audit defense matters. Previously, Klaus worked as the international tax director for ClubCorp Inc., an international tax specialist for Dresser Industries, Inc., the director of transfer pricing at Gardere Wynne Sewell, and as a senior manager for KPMG in Calgary, Canada, and Dallas, Texas.
4:00 - 5:00
Transfer Pricing Update: Mexico and South America
Benjamin Espindola, Mazars - Mexico City
- Dealing with emerging markets
- Transfer pricing in Mexico, Colombia, Ecuador, Venezuela, and Argentina
- Documentation requirements and information on penalties
- Examples of real-life audits and structures with these countries
 Since 2002, Benjamin Espindola has been responsible for tax and transfer pricing at Mazars, an international, integrated and independent organization, that specialises in audit, accounting, tax and advisory services. His focus is on international tax structures and planning and he has broad experience in transfer pricing.
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