Broadcast Date: Friday, March 13, 2020
from 12:00 pm to 1:00 pm (ET)

Overview:

Transfer pricing presents notable challenges and opportunities for multinational entities. Significantly, the rising disputes and sweeping impact of recent tax reforms have continuously reshaped its regulatory landscape and resulted in an intensified scrutiny. However, with a keen understanding of and proper compliance with the rules, transfer pricing can be substantial in positioning a business both locally and globally.

In this LIVE Webcast, transfer pricing experts David Hutchings (The Brattle Group) and Robin Hart (CRA) will provide the audience with an in-depth analysis of transfer pricing regulations, as well as recent updates and developments surrounding the topic. As experts, David and Robin will also discuss the best practices to overcome the challenges while maximizing opportunities.

Some of the major topics that will be covered in this course are:

  • Transfer Pricing Regulation in the 2020 Landscape: The Fundamentals
  • Recent Trends and Developments
  • The Impact of Global Tax Reform on Transfer Pricing
  • Risks, Challenges, and Pitfalls
  • Practical Tips and Strategies
  • What Lies Ahead

Credit:

Course Level:

Intermediate

 

Advance Preparation:

Print and review course materials

 

Method of Presentation:

On-demand Webcast (CLE)

 

Prerequisite:

General knowledge of transfer pricing

 

Course Code:

148399

 

NY Category of CLE Credit:

Areas of Professional Practice

 

Total Credit:

1.0 CLE

Speaker Panel:

David Hutchings, Principal
The Brattle Group

David Hutchings, a principal in The Brattle Group’s Toronto office, specializes in conducting economic analysis in complex tax, securities, and antitrust matters. Having assisted experts and attorneys for both taxpayers and taxing authorities, he has extensive experience in tax disputes and transfer pricing matters. He testifies, supports experts, and leads case teams in analyzing and developing economic and financial evidence to support attorneys. Among his experience, Mr. Hutchings has focused on developing innovative economic analyses to assess the best method for transfer pricing, assessing the profitability of transactions, and investigating the business purpose doctrine.

Robin Hart, Principal
Charles River Associates

Robin Hart is a Principal within CRA’s Transfer Pricing practice based in the San Francisco Bay Area. Robin is a highly regarded transfer pricing and tax economist with 18 years of experience serving clients in the life sciences, technology, and consumer products sectors. He has assisted taxpayers with their strategic objectives relating to the transfers and licensing of intangible property, alignment of supply chains, the establishment of high-value and shared service centers, and intercompany financing. Focused primarily on innovative Bay Area companies, Robin has executed on cross-border and domestic transactions involving cost-sharing and IP planning, post-acquisition integration, global BEPS alignment, the launch of new digital business models, and business restructurings. Prior to joining CRA, Robin was a Managing Director with Deloitte Tax in San Francisco.

Agenda:

David HutchingsPrincipal The Brattle Group

 

and

Robin HartPrincipal Charles River Associates

  1. OECD Updates
  • Taxation of the Digitalization of the Economy
    • Focus on Pillar 1 as that is more TP-centric
  • Action 13 expansion to developing countries
  • Re-evaluating Country by Country reporting
  1. OECD and International updates
  • OECD Financial transactions
  • re-characterization in Canada and Australia
  1. US Updates
  • IP Cases
    • Amazon Case
    • Facebook Case
  1. US Updates
  • Stock compensation case
    • Altera Case
      • tech companies’ procedure-base objections to the regulation
    • how to apply arm’s-length principle when there is no comparable (which may get us into allocation)

Date & Time:

Friday, March 13, 2020

12:00 pm to 1:00 pm (ET)

Who Should Attend:

  • Transfer Pricing Lawyers
  • Tax Lawyers
  • Transfer Pricing Advisers
  • Transfer Pricing Managers
  • Finance Executives
  • Financial Reporting Officers
  • Tax Managers and Directors
  • Financial Auditors
  • Accountants
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SPEAKERS

David HutchingsPrincipal
The Brattle Group
Robin HartPrincipal
Charles River Associates

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