Transfer Pricing Workshop
University of Washington (UW) School of Law
Graduate Program in Taxation
Transfer Pricing Valuation Institute
Monday, March 27, 2006
William H. Gates Hall – located on the UW main campus
Box 353020 Seattle, WA 98195-3020
Office: 206-616-8340, Fax: 206-685-4469
8 CLE/CPE credits for Washington approved
Register online at UW CLE
This Transfer Pricing Workshop will be oriented toward beginning to intermediate tax practitioners who have direct or indirect responsibility for performing transfer pricing analyses and/or preparing transfer pricing documentation or planning reports. The workshop will provide participants with hands-on training for performing functional and economic analyses, including preparing written transfer pricing documentation reports that will satisfy domestic and foreign documentation requirements. Emphasis will be given to the recently released proposed and final Section 482 regulations.
Program Highlights
- The conceptual foundation of transfer pricing as a tax issue, and its impact on the effective tax rate;
- Using transfer pricing planning and documentation to mitigate tax risks;
- How to prepare concise functional analyses that avoid inclusion of irrelevant information;
- How to write objective yet persuasive reports with analytic substance that will satisfy the regulation documentation requirements;
- How to cost effectively use financial databases for comparability analyses (including a live demonstration);
- Making the most efficient use of external advisors and economic experts;
- How to address controversial issues associated with recent final and proposed transfer pricing regulations;
- Ensuring consistent tax and financial statement reporting positions.
| Program Chairperson & Speaker | Program Speaker |
David F. Andrade, Ph.D. – Dr. Andrade is a recognized expert in the economics of transfer pricing and intellectual property and has been engaged as an expert consultant and testifying expert on many high-profile transfer pricing and tax valuation issues. Dr. Andrade is Director of the Transfer Pricing Valuation Institute and Assistant Professor of Law & Economics at the University of Washington School of Law, where he teaches courses and performs research in transfer pricing, taxation/valuation of intangibles and economic policy issues associated with intellectual property. Dr. Andrade received his Ph.D. in economics from the University of California at Davis. |
William E. Bonano, Esq. – Mr. Bonano's practice focuses on transfer pricing and international tax and he has significant experience with transfer pricing controversies. Mr. Bonano advises clients on transfer pricing and international tax issues including: cost sharing, technology transfer, section 6662 documentation, APAs, permanent establishment, debt vs. equity, foreign withholding, research credit, and other related issues. Before joining Pillsbury Winthrop LLP, Mr. Bonano was an International Special Trial Attorney with the Office of Chief Counsel, Internal Revenue Service, in San Francisco. Mr. Bonano received his J.D. from the University of Washington. |
Program Schedule
Overview of IRC Section 482 and OECD Transfer Pricing Guidelines
History of important transfer pricing controversies
Developing and communicating to financial reporting personnel how transfer pricing affects the tax provision
Managing external advisors within a fixed budget
What you can and cannot do without expert economic advisors
Sorting out relevant information from irrelevant information
Determining and quantifying the risks that matter
Adjusting style of prose for unbiased analytical perspective
Special considerations for tangible property associated with certain industries and products
Common mistakes associated with selecting the most reliable tangible property
How to address controversial issues associated with recent final and proposed transfer pricing.
Special considerations for provision of services associated with certain industries
Common mistakes associated with selecting the most reliable method(s) for services
How to address controversial issues associated with recent final and proposed transfer pricing
Spcial considerations for intangible property associated with certain industries, products and services
Common mistakes associated with selecting the most reliable intangible property
How to address controversial issues associated with recent final and proposed transfer pricing
How to cost effectively use financial databases for comparability analyses
Creating CUP/CUT analyses from internal and external sources of uncontrolled data
Advantages and disadvantages of transfer pricing software packages
Performing adjustments and quality control checks
