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Transfer Pricing Strategies for Foreign-Owned U.S. Companies

TRANSFER PRICING STRATEGIES FOR FOREIGN-OWNED U.S. COMPANIES

Cost Free
Presentation Length 1.0 hour

Recorded DateJune 10, 2021
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelBasic
Course Description

There are more transfer pricing adjustments at stake in the U.S. Tax Court than all other issues combined. Because transfer pricing is a popular way for a U.S. subsidiary to repatriate cash to a foreign parent, the IRS has an army of international examiners and economists ready to scrutinize a U.S. subsidiary's transfer pricing. This program will teach you the tools necessary to defend your client's transfer pricing.

Learning Objectives:


  • Determine all the intercompany transactions that a U.S. subsidiary may have with its foreign parent

  • Identify the different transfer pricing methods from which the parties must choose the best method

  • Recognize how to prepare the transfer pricing documentation to avoid penalties and prevent adjustments

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PLEASE NOTE: ARCHIVED WEBINARS DO NOT QUALIFY FOR CPE
Linkedin

Robert Misey, J.D., LL.M.

Reinhart Boerner Van Deuren s.c.
Chair of the International Department
rmisey@reinhartlaw.com
(312) 207-5456

Reinhartboernervan

Robert Misey leads the International Department for the law firm of Reinhart Boerner Van Deuren and is a former trial attorney for the IRS Chief Counsel (International) in Washington, DC. Robert is Chair of the International Tax Committee for the ABA and a member of the bar in California, Wisconsin, and the District of Columbia. He is also the author of the book, A Practical Guide to U.S. Taxation of International Transactions and Federal Taxation: Practice and Procedure.

About Our Presenter

Reinhartboernervan
At Reinhart Boerner Van Deuren, we know that every trusted relationship begins with understanding. That is why each of our committed attorneys takes the time to listen critically, learn the unique attributes of each client’s business, and work together to build a foundation for success that goes beyond providing legal services. While doing so, we draw upon an exceptionally broad base of experienced attorneys and deep knowledge of the industries and sectors we serve. This blend of active understanding grounded by informed perspective equips our attorneys to deliver uniquely creative, yet efficient, legal counsel.