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    Networking Seminars Inc.

    445 Park Avenue, 9th Floor

    New York, NY 10022

    877-500-1510

    info@networkingseminars.com

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    TAX PLANNING FOR THE BIOTECH & PHARMACEUTICAL INDUSTRIES
    OCTOBER 1 & 2, 2012 - PHILADELPHIA, PA

    In the past few years, very significant tax changes have occurred in the Biotech and Pharmaceutical industries.  Recent developments in contract manufacturing, supply chain management, the treatment of and repatriation of intellectual property back to the U.S. are a few of the significant developments that will be discussed. Learn how these new developments, opportunities and pitfalls will impact stocks and intangible assets.  Our panel of experts will discuss recent legislation, tax credits, IRS implications and recent activity by the IRS towards audit procedures.  Download Brochure

    This course is for biotech and pharmaceutical tax, finance and accounting executives, as well as, in-house counsel/corporate counsel representatives and others looking to gain a better understanding of the tax planning opportunities for U.S. multinationals in related industries with research and development and intellectual property with operations abroad.  There is no advance preparation or prerequisites but an understanding of U.S. international taxation is recommended. 

    Earn Up to 13 CPE and 13/11 CLE Credits (50/60 minute State)

    MONDAY, OCTOBER 1, 2012

    8:00 AM Continental Breakfast & Registration

    9:00 AM Overview of Recent Legislation & Tax Provisions

    • An update on FDA regulations and guidance
    • International Tax Reform
    • FIN 48 and Tax Provisions
    • Treatment of Intellectual Property
    • The Impact of Reform on Biotech Patent Strategies

    10:15 AM Refreshment Break

    10:30 AM Development & Transfers of Intellectual Property  

    • Key Tax Considerations
      • Treatment of IP-related of IP
        • Sale versus License of IP
        • Character, Source, Amortization
    • Consideration for related party transactions
    • Statutory and Regulatory Framework
      • Definition of “Intangible Property”
      • “All Substantial Rights” Standard
      • Litigation Update

    Brian Andreoli, Partner, Squire Sanders (US) LLP, New York, NY

    12:15 PM Networking Luncheon

    1:45 PM Licensing and Transfer Pricing Issues  

    • Scope of Section 482
    • Alternatives for Cross-Border Use of IP
    • Section 1.861-18 Rules
    • Trademarks
    • Specified Methods for Intangibles

    3:00 PM Refreshment Break

    3:15 PM Cost Sharing Regulations

    • Overview – Core Concepts
    • Requirements for a Cost Sharing Arrangement
    • 2011 Final v. 2008 Temp. Regulations
    • Grandfathered QCSAs
    • New Specified Methods
    • Case Studies

    Kenneth P. Christman Jr., Executive Director, Ernst & Young LLP, Washington, DC

    4:45 PM Question & Answers

    5:00 PM Seminar adjourns for the day

    TUESDAY, OCTOBER 2, 2012

    8:00 AM Continental Breakfast

    9:00 AM New Audit Focus and Resolving Tax Disputes

    • IP valuation relied on Comparable Uncontrolled Transactions and Residual Profit Split Method
    • IRS began exploring income, market cap methods, advancing these methods in examination settings
    • Fast Track Settlement (FTS)
    • Pre-Filing Agreements (PFA)
    • CAP and Pre-CAP
    • Utilization of Schedule UTP

    10:30 AM Refreshment Break

    10:45 AM Supply Chain Management

    • Global Supply Chains
      • Old new models
      • New models
    • Current trends in Supply Chain Management
    • Tax overlay
      • Tax planning is often overlooked
    • Recent Developments in Contract Manufacturing
    • Current “Best Practices” Structuring
      • Overview of drivers
      • Structures for global manufacturing
      • Structures for global services
    •  New Trends
      • OECD Pronouncements on Business Restructuring and Transfer Pricing Methods
      • IRS on contract manufacturing regulations
      • Realignment of APA program

    Greg Bryant, Partner, Cherry Bekaert & Holland LLP, Raleigh, NC

    12:15 PM Networking Luncheon

    1:15 PM R&D Tax Credits & Recent Developments

    • Research Credit Overview
    • Legislative Update
    • Current Audit Trends & Nexus Documentation Standard Recent Court Cases and Implications
    • Uncertain Tax Positions
    • Recommendations
    • Status of Global R&D Incentives
    • Biotech & Pharmaceutical Trends in R&D

    2:15 PM Cross-Border Mergers & Acquisitions and International Restructurings

    • Hot Topics in Transaction Forms  
    • Post-Acquisition Matters  
    • Impaired Investments 
    • Cash D Reorganizations
    • Selected Stock Basis Issues

    Devon Bodoh, Principal, KPMG LLP, Washington, DC
    Greg Featherman, Senior Manager, KPMG LLP, Washington, DC

    3:30 PM Seminar Concludes

    CONFERENCE LOCATION

    Sonesta Hotel Philadelphia (formerly the Crowne Plaza Hotel)
    1800 Market Street
    Philadelphia, PA 19103 Hotel
    Reservations :  1-800-Sonesta or 215-561-7500

    REGISTER NOW

    Fill in the Form and Submit
    Call: 877 500 1510
    Email: register@networkingseminars.com

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    Registration Fee

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      Continuing Professional Education Credit

      Networking Seminars Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.learningmarket.org

      To obtain CPE/CLE credits attendees will need to sign-in/sign-out each day at the time of arrival and departure to receive credits. This is a basic level course offering 13 CPE Credits. Networking Seminars Texas State Board of Public Accountancy as a CPE Sponsor ID is 009866.

      Continuing Legal Education Credit

      Networking Seminars is an approved CLE Sponsor by the State Bar of California until December 31, 2014.  We offer Continuing Legal Education (CLE) Credits in other States for those who request upon registration or at the seminar.  This seminar is transitional and non-transitional continuing legal education and is appropriate for new and experience attorney's. MCLE Boards will have final approval on the exact number of CLE credits granted.


      Cancellation Policy      : If you are unable to attend, you will be eligible for a credit in full to attend a future seminar less a $100 administrative fee. You must inform us at less 3 business days prior to the seminar date in order to be eligible for a credit. Credits are valid for one year and should be submitted upon registration at the next seminar. No refunds will be granted. If you have any questions or concerns and/or would like to view are complaint resolution policy please call 877-500-1510 or email: cs@networkingseminars.com