transcript   Transcript

Developments on Transfer Pricing

Recorded on: Feb. 8, 2017
Running Time: 01:02:33

Full Transcript:

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Taken from the Web Program International Tax Issues 2017 recorded February, 2017 in New York.

Developments on Transfer Pricing [01:02:33]
  • Government update on transfer pricing practice
  • BEPS and OECD developments affecting transfer pricing (including, Country by Country reporting)
  • Altera Corporation v. Commissioner, what does it mean (9th Circuit decision)?
  • IP planning – Notice 2014-54 (transfer pricing aspects)
  • Section 367(d) regulations (transfer pricing aspects)
  • Section 385 documentation

The purchase price of this segment includes the following article from the Course Handbook available online:

  • Determining the Form of PCT Payments
    Stephen Blough, Thomas M. Zollo
  • Background, Summary, and Implications of the OECD/G20 Base Erosion and Profit Shifting Project (JCX-139-15)

Presentation Material

  • Developments on Transfer Pricing
    David J. Canale, Rocco V. Femia, Thomas M. Zollo
Rocco V Femia ~ Miller & Chevalier Chartered
Thomas M Zollo ~ KPMG LLP
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