Transfer Pricing 101

Multinational corporations have a variety for intercompany transactions.  The U.S. parent may provide managerial, technical or administrative services.  There may also be a transfer or sale of intellectual property assets.  These intercompany transactions affect how income is allocated and how to determine the costs of goods and services affects corporate tax reporting. This webinar will provide a basic overview of transfer pricing in regard to these transactions.  We will discuss everything you wanted to know about transfer pricing, but were afraid to ask.

Presentation Objectives:

• The application of IRC Section 482 to related international parties  
• The arm’s-length standard and the “best method rule”
• The application to transfers of tangible and intangible property
• Use of cost sharing arrangements
• The application to intercompany loans and advances
• The application to intercompany services
• Contemporaneous documentation and reporting requirements  
• Audit strategies

Upon completion of this webinar participants will be able to:

• Understand how a company uses transfer pricing in computing controlled transactions in order to satisfy various financial reporting, tax and regulatory requirements
• Determine the “best method” to use for intercompany transactions
• Understand what a cost sharing arrangement is and other intercompany agreements when transfer pricing is used for intangible assets, loans, advances, tangible property and performance of services
• Understand the importance of gathering information for reporting requirements and preparing transfer pricing documentation

Speaker

Robert J. Misey, Jr. is a shareholder at Reinhart Boerner Van Deuren in the firm's Tax and Business Law Departments and co-chair of the International Department. He concentrates his practice in the areas of international taxation and tax controversies. Mr. Misey works with a wide range of clients from a variety of industries including manufacturing, service, energy, retail and entertainment. For foreign owned clients, Mr. Misey coordinates with the client's global tax minimization strategy, using repatriation techniques to minimize U.S. withholding taxes. For U.S. based multinationals, he helps clients maximize foreign tax credits and avoid U.S. taxation of foreign earnings to reduce the client's overall effective tax rate.  Mr. Misey's previous legal experience includes nine years as an attorney for the IRS. While he was with the IRS, he served as an international tax attorney in Washington, DC and a trial attorney and international tax specialist in San Jose, California. He also managed the international tax services for a region of Deloitte & Touche for three years. 

He has published numerous articles and is an author of the books entitled U.S. Taxation of International Income and International Provisions of the Tax Reform Act of 2004, both published by CCH. Mr. Misey also teaches international taxation at the Master of Tax program in the University of Wisconsin system. Mr. Misey received his Juris Doctor and Master of Business Administration degrees from Vanderbilt University and his Master of Laws in Taxation, with high distinction, from Georgetown University where he was the graduate student editor of The Tax Lawyer. 

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