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.
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.