Transfer Pricing Roundtable Events
NABE members can access webinar recordings on the Podcasts page. For archived materials from past events, please email us.
Past Events:
NABE Transfer Pricing Safe Harbor Progress Report
Monday, July 8, 2013
12:00 pm - 1:15 pm ET
Speakers:
Patricia Lewis, Caplin & Drysdale
Bill Morgan, IRS
John Hughes, IRS
Slide presentation (PDF)
As a follow up to last year's NABE Transfer Pricing Symposium Safe Harbor Challenge, we will host a panel discussion about the status of the IRS' work on safe harbors. This spring the IRS asked for comments from the transfer pricing community about safe harbors and the OECD released its revisions to the Transfer Pricing Guidelines with respect to safe harbors. Bill Morgan and John Hughes, who are leading the IRS' initiative, will provide a progress report, with Pat Lewis moderating the discussion and offering perspective on the OECD guidance. Join us as our panel discusses the issues and ideas surfaced to the IRS about the potential US use of transfer pricing safe harbors. The webinar will be interactive with time set aside for questions from the audience.
Registration is FREE for NABE members and the public.
Register now
2013 NABE Transfer Pricing Symposium
July 30-August 1, 2013
Arlington, VA
Also, be sure to register for the 2013 NABE Transfer Pricing Symposium! This year's event will continue to build on the energetic engagement of our Transfer Pricing community. The 3rd annual Transfer Pricing Symposium, will take place July 30-August 1, 2013 at the Sheraton Crystal City in Arlington, VA.
Join your Transfer Pricing colleagues to network and share the latest insights and ideas.
Past Events:
Using Transfer Pricing Principles in Excise Tax Applications
Wednesday, February 20, 2013 11:00 am - 12:00 pm ET
Speakers:
Jill Weise, Managing Director, Duff & Phelps, moderator Karen Kirwan, Executive Director, Ernst & Young, moderator
Kelly Grady, Executive Director, Ernst & Young, LLP Thomas Herr, KPMG Tony Smith, VP of Tax, Thermo
Slide presentation
The panel will discuss using transfer pricing principles to value goods for excise tax purposes, such as the new medical device excise tax. These taxes usually focus on the manufacturer of the product and the price at which they would sell the product to a wholesaler. Since business models don’t always incorporate such a sale, taxpayers are left to recreate that theoretical price and for examiners to attempt to audit it despite limited Industry knowledge. Join us as our panel of economic consultants discuss the issues with a taxpayer. The webinar will be interactive with time set aside for questions from the audience.
Registration is FREE for NABE members and the public.
View podcast
Adjusting the Economist Function at the IRS: Challenges and Opportunities
Thursday, March 1, 2012 12:00 pm - 1:00 pm ET
Speakers:
Jill Weise, Ceteris, moderator Matt Hartman, Program Manager, Transfer Pricing Technical Specialists (LB&I) Russell Kwiat, Branch Chief, Advance Pricing Agreement Program (Chief Counsel)Bill Morgan, Senior Economist, Transfer Pricing Operations (LB&I)
Slide presentation
The panel will discuss the economist role at the IRS in the new Advance Pricing and Mutual Agreement program (APMA) and in the transfer pricing field operation. Over the last six months, the organization of the IRS related to Transfer Pricing has changed significantly. The panelists will talk about the economist function in relation to these organizational changes and provide some insight on how the roles and responsibilities have changed and how they will stay the same. They will also provide perspective on the relationship between the APMA economists and the field economists and their respective roles and responsibilities. The webinar will be interactive with time set aside for questions from the audience.
Registration is FREE for members of the NABE Transfer Pricing Roundtable and the public.
Click here to purchase and download the podcast.
“Profit Potential – Best Practices When Applying the CUT/CUP Method”
Tuesday, January 10, 2012
12:00 pm - 1:30 pm ET
Speakers
David R. Jarczyk, President, ktMINE — Roundtable Moderator
Andrew Parsons, Competent Authority Analyst, IRS
Hareesh Dhawale, Supervisory Competent Authority Examiner, IRS
Gene Tien, Director, Baker and McKenzie Consulting LLC
Slide Presentation
Topic Overview:
As tax authorities and organizations such as the OECD work to define, scope, and promote internationally accepted guidance surrounding the definition, valuation, and treatment of intellectual property, many transfer-pricing practitioners are concerned about how to effectively analyze profit potential in the intercompany transfer of IP.
Led by services industry and tax authority experts, this roundtable discussion will provide guidance on evaluating profit potential under the CUT or CUP methodology. The panel will cover key comparability factors that should be addressed and will also share best practices for:
- Establishing similarity of profit potential of the IP under the US transfer pricing regulations and the OECD Guidelines;
- Utilizing rules of thumb or industry averages;
- Examining critical aspects of an IP transaction, including factors that can derail the defensibility of an analysis if left unchecked;
- Locating, screening and validating data based on comparability factors and information resources, including internal agreements; and
- Applying adjustments and proving “reasonableness” in a way that will resonate with your audience, including those in controversy, audit, or litigation settings.
Registration is free for members of the NABE Transfer Pricing Roundtable and the public. The podcast is now available.
Click here to download the podcast.
Speaker Bios
David R. Jarczyk, President, ktMINE
Mr. Jarczyk manages the overall business operations and product development of this intellectual property data and information services firm. Prior to joining ktMINE, he was a transfer pricing economist at large consulting firms where he performed numerous valuations of intangible property and IP-related deals related to IP expert witness and damages cases, transfer pricing, tax restructurings, IP contributions, and similar matters. Mr. Jarczyk is a published author and frequent speaker at LES, ASA, CICBV and other events, including internal global tax authority meetings.
Mr. Jarczyk holds an MBA and BS in Economics and Finance from DePaul University, Chicago, Illinois and a CLP designation.
Andrew Parsons, Competent Authority Analyst, United States Internal Revenue Service.
Mr. Parsons works as an analyst and economist for the Internal Revenue Service on transfer pricing matters such as tangible property, services, and intangible property in multiple industries. Prior to joining the IRS, Mr. Parsons was Vice President at Precision Economics and managed projects in such milestone transfer pricing cases as GlaxoSmithKline Holdings (Americas) Inc. v. Commissioner of Internal Revenue. He has spoken at US and European conferences regarding various transfer pricing matters.
Mr. Parsons has a B.S. and M.E. in Operations Research and Industrial Engineering from Cornell University, and an M.B.A from Georgetown University.
Hareesh Dhawale, Supervisory Competent Authority Examiner, IRS
Mr. Dhawale leads a team focused upon transfer pricing economics in support of the IRS’ U.S. Competent Authority and International Coordination. Prior to joining the IRS, he worked in the national office of some large accounting firms where he conducted numerous transfer pricing studies for clients in a diverse group of industries and sectors. Mr. Dhawale has also published numerous articles on transfer pricing matters.
Mr. Dhawale earned a JD from the George Washington University National Law Center, a PhD in economics from the University of Maryland at College Park, is a Member of the District of Columbia and Virginia bars and is a CFA charterholder.
Gene Tien, Senior Economist, Baker & McKenzie Consulting LLC's Palo Alto, California Office.
Dr. Tien advises businesses on transfer pricing and economic consulting matters relating to global pricing strategies, intangible valuations, and U.S. and international tax controversy considerations. Dr. Tien's practice is predominantly focused on supporting technology companies. He works with firms across numerous sectors including biotech, pharma, web computing, the electronics industry, and the consumer product goods space. He regularly publishes and presents on matters relating to transfer pricing, IP, licensing, and Asia development issues.
Dr. Tien has a degree in Economics from the University of Washington and a doctorate in Economics from Northwestern University.
Transfer Pricing Roundtable Webinar:
"IP Valuation for 482 and Financial Reporting – Contrasts and Pitfalls"
Tuesday, October 11
11:00 am - 12:30 pm ET
Speakers:
Karen Kirwan, Executive Director of International Tax Services and Transfer Pricing, Ernst & Young, moderator
Jill Weise, Managing Director, Ceteris, moderator
Michelle Garcia, Director of Transfer Pricing, Amazon.com
Thomas Herr, Principal - Economic and Valuation Services (EVS), KPMG slide presentation
Speaker Bios:
Michelle Garcia
Michelle Garcia recently joined Amazon.com as its Director of Transfer Pricing and has over 20 years of tax/transfer pricing experience. Prior to her role at Amazon, Ms. Garcia was a Director at AFC Consulting Inc., and a Senior Director of Transfer Pricing at Covidien Plc (formerly Tyco Healthcare). In her various positions, Ms. Garcia has developed vast experience in a variety of transfer pricing areas including issues associated with business and intangible valuation.
Ms. Garcia holds a MPA –URP in Economics & Urban and Regional Planning from Princeton University and a BA in Economics and Mathematics from the University of California, Santa Cruz.
Thomas Herr
Thomas Herr leads KPMG’s Economic and Valuation Services (EVS) practice in Minneapolis. He has over 15 years of experience advising businesses on intragroup transfer pricing policies, transfer pricing planning opportunities, and on business and intangible valuation issues. During this time, Mr. Herr spent over two years in London working with companies in the United Kingdom and the rest of Europe implementing OECD-compliant transfer pricing systems.
Mr. Herr has a Master’s Degree in Economics from the University of St. Gallen (Switzerland), a Master’s Degree in International Relations from Johns Hopkins University and holds the CFA designation.
Click here to sign in and download the podcast.
"The Elephant in the Room: The Great Debate around Appropriate Discount Rates in TP Analyses"
Tuesday, February 1, 2011
2:00 PM (EST)
Speakers:
Paul Clark, Director and Certified Financial Analyst, Ceteris
Russell Kwiat, Economist Manager, Advance Pricing Agreement Program (APA), Internal Revenue Service
John Wills, Ph.D. economist and retired partner, Ernst & Young
Slide presentation
Paul Clark, Director and Certified Financial Analyst, Ceteris’ valuation practice. Mr. Clark has advised businesses and business owners on mergers and acquisitions, recapitalizations, leveraged buyouts, ESOPs and corporate planning matters. Additionally, Mr. Clark has provided numerous business enterprise, equity and intangible asset valuations for financial reporting and tax compliance purposes. Mr. Clark a MBA degree from the John M. Olin School of Business at Washington University and a MS degree in Mechanical Engineering from the University of Missouri.
Russell Kwiat, the Economist Manager at the IRS's Advance Pricing Agreement Program (APA). In his role, Mr. Kwiat oversees all economic analyses within APA, serves as the principal APA economist for many cost sharing cases, and participates in various regulation committees such as those focused on cost sharing and 367(d) issues. Mr. Kwiat has degrees in economics and finance from The Wharton School of the University of Pennsylvania and The Robert H. Smith School of Business at the University of Maryland.
John Wills, Ph.D. economist and retired partner in Ernst & Young’s San Jose, California office. In his role, Dr. Wills was the head of transfer pricing for the Pacific Northwest region. John’s practice was heavily oriented toward technology companies. He has worked with large numbers of companies in computer software and hardware, semiconductors, biotechnology, and pharmaceuticals; with particular focus on transactions in intellectual property and intangibles. He is especially experienced in the design and implementation of R&D cost sharing arrangements. Since retiring from Ernst & Young last year, John continues to consult on a part-time basis.
This is a FREE event for NABE members and the public.
To register for this upcoming event, please click here.
"Revised OECD Transfer Pricing Guidelines: Toward Convergence?"
Thursday, October 14
11:00 AM (ET)
Speaker:
Karen Kirwan, Ernst & Young, moderator
Jill Weise, Ceteris, moderator
Dr. Michael McDonald, Office of Tax Policy, U.S. Department of Treasury
Slide presentation
After the successful launching of it Transfer Pricing Roundtable, NABE is pleased to announce the second TP RT teleconference, "Revised OECD Transfer Pricing Guidelines: Toward Convergence?," featuring Dr. Michael McDonald on Thursday, October 14, at 11:00 AM (EDT). Michael McDonald, US Treasury representative to the OECD Working Party 6, will offer his views about the recently revised OECD TP Guidelines. He will share his thoughts about the most significant changes to Chapters I-III and insights on the new Chapter IX. In addition, Dr. McDonald will preview the OECD's next big Transfer Pricing initiative around intangibles. Audience questions are encouraged as we know this topic is of great interest within our Transfer Pricing community.
This teleconference will be free to the public.
Click here to sign in and register.
Inaugural Teleconference:
"Recent US Transfer Pricing Developments: New, Yes . . . but Improved?"
Thursday, June 24, 2010
11:00 AM (EDT)
Speakers:
Mark Bronson, Managing Director, Ceteris slides
Mike Denning, Principal, Ernst & Young
Kate Sullivan, Director, Ceteris slides
In order to gauge the interests and priorities of participants, the first TPRT call will include several topics. It will cover the impact of the proposed FIN48 disclosure rules, applications of the income method in valuing intangible property transfers, and the new USC section 7701 codification of economic substance doctrine. There will also be time reserved at the end of the call for participants to contribute comments and input about topics for future teleconferences.
Click here to download a podcast of the webinar.