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Wednesday, November 14
Tracy Gomes, Chief Economist, McDermott Will & Emery LLP
Synopsis: This webcast focused on the recent revisions proposed in Chapter VI of the OECD's Transfer Pricing Guidelines. Transfer pricing experts Cym Lowell and Tracy Gomes from McDermott Will & Emery LLP walked through what is new and different in the discussion draft and key areas of controversy for multinational corporations. You will also get insight into:
- Why are financial valuation principles, goodwill, and local market intangibles are such an important issue?
- The likelihood of change before finalization
- Planning and documentation for intangibles transactions
October 24, 2012
Synopsis: This webcast discussed the Microsoft vs. Chainbridge case and the implications it may have on your state transfer pricing.
During this webcast, we also covered:
- Lessons learned from the Microsoft Corporation, Inc. v. Office of Tax and Revenue case
- How to more appropriately use the Comparable Profits Method to defend your state's transfer pricing position
- Traditional domestic transfer pricing approaches that utilize domestic sales subsidiaries or domestic intangible holding companies
Wednesday, August 15, 2012
Synopsis: During the webcast, we will demonstrate and discuss the significant evidence gap that can stem from relying on research that focuses on SIC codes vs. IP exploited at the transactional level and more, including:
- Insight into the history and use of industrial classification
- Detailed guidance on approaches and industry data resources that can help mitigate risk
- Efficient ways to find all relevant, comparable royalty-rate benchmarks
PART 2: A CLEAR PICTURE INTO POLICY & MONITORING
Tuesday, June 5, 2012
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Thursday, June 14, 2012
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Speaker: Ignaz Wong, Manager, ONESOURCE Transfer Pricing
Synopsis: Transfer pricing for financial transactions is no longer an issue just for banks, insurance and asset management firms. Establishing a comprehensive transfer pricing policy that covers current and upcoming intra-group financial transactions will help you stay ahead of the curve with complex corporate treasury functions.
This webcast covered the primary treasury functions associated with cross-border intercompany funding including:
- An overview of corporate treasury and intercompany financing
- Intercompany debt arrangements and guarantees
- Cash pooling and factoring
Speaker: Saumyanil Deb, PhD Manager for ONESOURCE Transfer Pricing
Synopsis: We will examine what the latest revisions mean for multinational corporations and transfer pricing professionals. During this webcast we will address the following:
- A current overview of the OECD Guidelines, including revised Chapters I-III
- The replacement of traditional transaction methods and transactional profit methods
- Background on why the OECD made these changes and their implications for tax professionals
Speakers: Cym Lowell, Partner, Gardere Wynne Sewell LLP
Bret Wells, University of Houston Law Center
Synopsis: Our three-part webcast series, entitled The Obama Administration & Transfer Pricing Evolutions, is coming to an end. The earlier interactive sessions, featuring industry experts Cym Lowell and Bret Wells explained the Obama administration's proposals to include transfer pricing provisions in the United States debt reduction plan.
You don’t want to miss part three of this series, which will focus on planning considerations in the current environment for both the U.S. and foreign-based MNE groups.
Speakers: Cym Lowell, Partner, Gardere Wynne Sewell LLP
Bret Wells, University of Houston Law Center
Synopsis: Part Two of the series, The Obama Administration and Transfer Pricing Evolutions, will cover Chairman Camp and the very interesting territorial tax proposal as an element of the serious discussions that are ongoing in Washington. Presenters will examine:
- Details of the plan
- Its tax base defense mechanisms
- Thoughts about their failure to actually provide any improvement over the current environment.
Speakers: Jeff Cozzo, New Business Development, ktMINE
David Jarczyk, President, ktMINE
Synopsis: Around the world, analysts are experiencing a heightened need to provide fact-based evidence when applying the CUT/CUP method. At the same time, government authorities are taking greater care to dissect and dispute the comparability of chosen transactions to the tested transaction, point-by-point. To ensure a defensible position, meticulous attention should be paid to these factors of comparability when conducting intangible property analysis using third-party licensing agreements. When evaluated fully, the text of a license agreement can provide valuable details justifying, or negating, specific factors of comparability and can provide ample evidence supporting a direct and reliable measure of an arm's length result.
Speakers: Cym Lowell, Partner, Gardere Wynne Sewell LLP
Bret Wells of the University of Houston Law Center
Synopsis: Part One of this series will discuss the history of international law and treaty policy in the United States, including the objectives of comprehensive international tax reform. Industry experts will discuss:
- The elements that make the current structure of comprehensive international tax reform objectives non-functional
- Pending Obama administration proposals compared to the imperatives of tax reform
- The current status of Congressional Super-Committee work
- Transfer pricing evolutions and the potential implications it could have on multinational corporations and transfer pricing professionals
Speakers: Tracey Rossow, Senior Product Specials, Global Technology Solutions
Synopsis: With the increased focus on international tax, multinational tax departments have worked hard to establish arm’s-length transfer pricing policies to govern their day-to-day transactions. However, ensuring that those policies are communicated, implemented, and adhered to by the rest of the company requires a significant allocation of resources and time. This can still lead to inconsistencies and errors resulting in large adjustments at year end.
Join us for a webcast entitled Minimizing Risk in Transfer Pricing Operations:
- Find out how you can better manage and validate compliance with transfer pricing policies
- Hear about challenges faced by other multinational corporations in obtaining information related to the intercompany transaction process
Tracey Rossow, senior product specialist, will highlight the benefits of global pricing compliance and the issues surrounding accounting for transfer pricing.
Speakers: Tracy Gomes, Director and Chief Economist, Tax, Gardere Wynne Sewell LLP
Cym Lowell, Partner, Tax, Gardere Wynne Sewell LLP
Gerald J. Mehm, Sr. Managing Director and Sr. Vice President, American Appraisal
Synopsis: This webcast examines how valuation, financial accounting, and transfer pricing overlap far more than is often thought. MNEs commonly undertake global planning, structuring, and restructuring for the purpose of streamlining their business operations. These efforts also have material income tax consequences in all affected jurisdictions. In turn, the valuations and tax consequences will have a material impact on the MNE's financial accounting results before and after the transactional planning. A question that will often need to be addressed is whether the normal type of financial accounting valuation undertaken with respect to a transaction can be used for transfer pricing purposes, or whether such appraisal work can be modified to address the transfer pricing requirements. This webinar also discusses purchase price allocations, which are used for financial accounting purposes.
Speakers: Andrew Weaver, Product Manager for ONESOURCE Transfer Pricing
David Jarczyk, President, ktMINE
Jeff Cozzo, New Business Development, ktMINE
Synopsis: This webcast demonstrates the newly released Documenter version 6.0 of ONESOURCE Transfer Pricing, displaying a series of enhancements designed to increase flexibility and functionality for a tax department's ongoing transfer pricing needs. Specifically, the newest features expand upon the transaction-based analysis process, provide users with efficient ways to upload uncontrolled transaction data, enable additional filter criteria options for European comparable searches, and facilitate your IP analysis with seamless access to ktMINE's Royalty Rate Finder© Database and new Project Module©.
Speakers: James Harold McClure, Sr. Manager for ONESOURCE Transfer Pricing
Synopsis: This webcast will discuss how the Modified Resale Price Method can be used to determine the arm's length gross profit margin for a related party distributor in situations where the traditional Resale Price Method cannot be utilized.
Speakers: Tracy Gomes, Director and Chief Economist, Tax, Gardere Wynne Sewell LLP
Cym Lowell, Partner, Tax, Gardere Wynne Sewell LLP
Paul McGuire, Sr. Manager, Tax Reporting, Dean Foods Company
Synopsis: Once transfer pricing policy has been developed and an operational model is developed, the policy needs to be coordinated with transfer pricing requirements and made operational. Join us for part two of this webcast series, which will highlight management and data and the practical reality of implementation of transfer pricing policies. The webcast will cover transfer pricing theory and practice, steps to developing an effective transfer pricing practice, and coordinating operation transfer pricing with FIN 48, uncertain tax positions schedule, APAs, Examinations, and Controversies.
Speakers: David Jarczyk, COO, ktMINE & Jeff M. Cozzo, Business Development, ktMINE
Synopsis: During this informative webcast, you will learn why conducting a comprehensive analysis on industry profitability is critical along with how:
- Utilizing the Porter's Model of Competitive Forces helps develop insight into what drives an industry's profit
- Industry drivers allow us to better understand the relative contributions of each entity within a corporate group and thus benchmark intangible property transactions between entities more accurately
- The Value Chain represents the systematic way of examining all the activities a firm performs, how they interact, and their relative value
Speakers: Andrei Enoiu and Denise Guthrie, Senior Managers for ONESOURCE Transfer Pricing
Synopsis: With the combination of increased transfer pricing scrutiny, desire for greater control, and shrinking departmental budgets, we continue to see a trend in bringing the transfer pricing documentation process in-house. This webcast will demonstrate how several corporations have utilized the Documenter version of ONESOURCE Transfer Pricing to gain greater control over their transfer pricing documentation process.
This webcast will discuss the following scenarios:
- A multi-billion dollar company who uses the software as a member of the Compliance Assurance Program (CAP)
- A manufacturing company who uses the software to update studies
- A company who uses the software for lower risk work but still leverages advisors for higher risk work
- A privately held company who uses the software as the primary tool to lower and manage their effective tax rate
Speakers: Tracy Gomes, Director and Chief Economist, Tax, Gardere Wynne Sewell LLP, Cym Lowell, Partner, Tax, Gardere Wynne Sewell LLP, Paul McGuire, Sr. Manager, Tax Reporting, Dean Foods Company
Synopsis: Review part one of the webcast series, which will highlight designing transfer pricing policies and internal procedures. This webcast will examine overall design, focusing on practical realities of making the system work in a multinational environment covering the following:
- Evolution of transfer pricing management
- Evolution of transfer pricing enforcement
- Need for heightened transfer pricing management
Speakers: Dr. J Harold McClure- Sr. Manager, ONESOURCE Transfer Pricing
Synopsis: This webcast recording will broaden knowledge on the topic of Intercompany Loans and Guarantees. Dr. McClure will discuss the following: regulatory environment, key terms of a loan agreement, credit risk, exotic features, intercompany loan guarantees, and intercompany factoring.
Speakers: Dr. Harold McClure, Senior Manager, ONESOURCE Transfer Pricing & Jeff M. Cozzo, Business Development, ktMINE
Synopsis: Our discussion will contrast several approaches to evaluating arm's length royalty rates including market approaches based on the same intangible asset and market approaches based on other intangible assets in the same sector, which is an approach that sets the royalty to the residual of licensee profits net of a routine return. The webcast will also cover approaches that allow for a share of residual profits to be retained by the licensee. While the IRS often favors the approach that sets the royalty to the residual of licensee profits net of a routine return, foreign tax authorities often argue that this approach overestimates the arm's length royalty rate.
Speakers: Mark Martin and Mark Horowitz with Gardere Wynn Sewell LLP
Synopsis: This webcast will address the definition of intangible property for transfer pricing purposes, including difficult issues such as work force in place, routine versus non-routine intangibles, and other evolving definitional matters. Our speakers will highlight routine versus non-routine intangibles, the current OECD transfer pricing initiative on intangible property transactions, and selecting the most appropriate method for pricing intangible property transactions.
Speakers: David Jarczyk, COO, ktMINE
Jeff Cozzo, Business Development, ktMINE
Synopsis: The focus of this webcast is to share key strategies for locating and disaggregating intangible licensing agreements for use in transfer pricing issues and expert witness litigation. Our speakers, David Jarczyk and Jeffrey Cozzo, will also provide insight on performing thorough due diligence to identify and address any hidden conditions that may affect the defensibility of an asset valuation.
Speakers: Dr. J. Harold McClure, Sr. Manager of ONESOURCE Transfer Pricing Jenny Bluvshteyn, Training Coordinator
Synopsis: This webcast will take the theory applied in the Transfer Pricing 101 (part 1) webcast and demonstrate how the Documenter version of ONESOURCE Transfer Pricing can apply the principles and produce transfer pricing documentation for any corporation in-house.
Speaker: Dr. J. Harold McClure, Sr. Manager, ONESOURCE Transfer Pricing
Synopsis: This webcast will walk through the basic principles of transfer pricing, including the objectives of a transfer pricing report, the regulatory environment, and how to prepare the final transfer pricing report.
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