Working with the Service Regulations
During the past 5 years, transfer pricing for services has become increasingly complex as companies continue to globalize operations. Recent global economic challenges have also intensified tax authority challenges to companies’ transfer pricing as a potential local revenue enhancer. Section 1.482-9 includes major changes to historical U.S. rules and practices. This webinar will provide a detailed explanation for the Service Regulations, Section 1.482-9 including:
- What Costs can be Allocated under Section 1.482-9 and How
- Does your Company Qualify for the Services Cost Method?
- Intercompany Agreements and Planning Opportunities
- Related Controversies and Double Taxation
Upon completion of this webinar, participants will be able to:
- Understand the differences between the “old” and “new” benefit tests, the “sole effect” test and stewardship
- Understand the various intercompany agreements for planning opportunities
- Avoid double taxation on intercompany services
- Handle tax controversies arising from intercompany services
Brian Trauman is a Tax Principal in KPMG’s Economic and Valuation Service practice, and is the U.S. East region leader for transfer pricing controversy services. Brian helps clients manage and resolve disputes and respond to the challenges that come with transfer pricing controversies, whether related to intercompany pricing between the U.S. and other countries or between U.S. states. Prior to joining KPMG, Brian was a partner with a multinational law firm, where he was responsible for assisting multinationals with a wide range of both U.S. and non-U.S. tax controversy and transfer pricing matters, including transfer pricing structures and supply chains, advance pricing agreements, mutual agreement procedures, documentation, intercompany agreements, and audits, appeals, and litigation. His clients include leading companies in such industries as the automotive, agricultural, chemical, finance, oil and gas, technology, and telecommunications sectors. Brian has responded to state, federal and foreign information document requests, liaised with exam teams, drafted protests to notices of proposed adjustments, presented cases to appeals teams, and participated on litigation teams. In addition, he has interacted with Congress, the IRS, Treasury, and the OECD for changes to Income Tax Code, Regulations, and other guidance. Brian also has served as an attorney-advisor with the U.S. Tax Court. Brian is a frequent speaker and writer on a wide range of transfer pricing and controversy topics, including the IRS’s Schedule for Uncertain Tax Positions, business restructurings, implementing the US services regulations, valuation of intangibles, choice of administrative and judicial forum, and advance rulings. These engagements include presentations and publications for ABA, BNA, OFII, IBFD, the United States Tax Court and other events. Brian has also guest lectured on transfer pricing topics for NYU’s LL.M. program, and for the Republic of Colombia’s international tax examiners.