Transfer Pricing Dispute Resolution Strategy (Currently Unavailable)

Date: Monday, November 22, 2021
Instructor: William J. Seeger
Begin Time:  11:00am Pacific Time
12:00pm Mountain Time
1:00pm Central Time
2:00pm Eastern Time
CPE Credit:  1 hour for CPAs
1 hour Federal Tax Related for EAs and OTRPs
1 hour Federal Tax Law for CTEC

By its very nature, intercompany pricing concerns at least two tax authorities – the IRS and one foreign tax authority, and possibly more. There are so many dispute resolution mechanisms available to Taxpayer’s today that it becomes challenging to keep their purpose and nuances clearly in mind. The traditional tools still exist, such as IRS Exam and Appeals. However, newer programs have emerged, such as Advanced Pricing Agreements, Competent Authority, the Mutual Agreement Program, and Tax Treaties, providing much-needed flexibility to taxpayers in tackling a dispute resolution matter.

With so many avenues available to taxpayers to resolve disputes with the IRS, it appears challenging to pick the right programs specifically tailored to deal with a taxpayer’s exposure. As a former IRS special agent Economist, and Big-Four Principal, I have experienced firsthand what these programs have to offer. Picking the right program for your situation is your best bet for a favorable outcome.

This webinar reviews the essential characteristics of these programs so you can confidently navigate this mysterious IRS world. The primary purpose of each dispute resolution program is emphasized so you understand how the various programs fit together as a coherent whole. Moreover, the strategies presented will allow you to proactively design the best dispute resolution path to mitigate the risk of paying too much tax. The principles you learn here are applicable in other tax jurisdictions should your Company run afoul of the Tax authorities of foreign governments.

Multi-national Company Dispute Resolution today is no longer confined to a unilateral affair with the IRS. Instead, it is a multilateral one with the IRS and other foreign governments simultaneously interacting jointly on a Transfer Pricing matter.

Who Should Attend
Essential for all practitioners who deal with cross-border tax compliance and planning issues — and is especially important today as the IRS has aggressively increased scrutiny and enforcement activity in the international tax area? Professionals in public practice and industry will benefit from this program. Business tax and finance executives, directors, managers and staff; CPAs; Enrolled Agents; tax preparers and staff; accountants, attorneys, and financial advisors who work with and advise businesses and individuals with cross-border operations, activities and issues.

Topics Covered

  • IRS Exam
  • IRS Appeals
  • Advanced Pricing Agreement Program
  • Competent Authority/Mutual Agreement Program
  • BEPS Dispute Resolution procedures
  • Role of Tax Treaties in multilateral dispute resolution
  • Dispute resolution planning: the optimal path through the thicket of rules and procedures
  • Leveraging Strategies to control the resolution and outcome of the disputed tax matters

Learning Objectives

  • Identify the role of the various IRS players at each stage of the Dispute resolution process
  • Recognize how dispute resolution programs work with an emphasis on intercompany pricing
  • Identify opportunities where dispute resolution planning can mitigate audit and tax risk
  • Recognize the relevant steps to employ the Dispute resolution programs
  • Differentiate between unilateral and multilateral approaches

Level
Basic

Instructional Method
Group: Internet-based

NASBA Field of Study
Taxes (1 hour)

Program Prerequisites
None

Advance Preparation
None

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