Register for the 10th Annual NABE
Transfer Pricing Symposium, convening online
July 21-23, 2020.
This year's TPS is going digital! Registration is
FREE for NABE members.
Each year, the NABE Transfer Pricing Symposium gathers leading professionals from business, government, and consulting firms to
discuss and
debate the most relevant economics topics in the field of transfer pricing.
The NABE TPS uniquely focuses on the economics of transfer pricing and the latest technical thinking in this area.
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Matt Andrew
OECD |
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Stewart Brant
OECD |
This year's program will feature an update on OECD Pillar One developments with Matt Andrew and Stewart Brant from the OECD.
The Symposium planning committee includes
Karen Kirwan, CBE, of the Internal Revenue Service,
Donna McComber, of Baker McKenzie Consulting LLC,
Michael McDonald of EY,
Perry Urken of Economics Partners, LLC, and
Jill Weise, CBE, of Duff & Phelps.
Program
| Tuesday, July 21 |
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| 11:00am-11:15am |
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Welcome / Introduction |
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Perry Urken, Economics Partners
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| 11:15am-12:30pm |
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Panel 1: Transfer Pricing Implications of the COVID-19 Pandemic |
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Helena Aten, EY
Denise Guthrie, Carrier
Kartikeya Singh, PwC
Inigo Zapater, IRS
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This session will explore the transfer pricing implications of the COVID-19 pandemic and its related aftermath. Among the issues the panel expects to cover are: Considerations around the contractual relationships between related parties and the economic realizations of risks; allocation of operating losses and certain governmental assistance in response to COVID-19; potential lack of comparables in assessing / incorporating COVID-19 impact; how the transfer pricing position taken by companies given COVID-19 would impact characterization and future transfer pricing positions; and potential difficulty in applying current TP rules and guidelines due to COVID-19, for taxpayers, tax authorities, and practitioners. |
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| 12:30pm-1:15pm |
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Break |
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| 1:15pm - 2:30pm ET |
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Panel 2: Transfer Pricing Insurance: a new way of thinking about tax certainty? |
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Clark Armitage, Caplin Drysdale
Austin Cahill, Atlantic Group
Jesse Rosenthal, Discovery
Perry Urken, Economics Partners
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| Wednesday, July 22 |
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| 11:15am-12:30pm |
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Panel 3: Considerations Regarding Implicit Support from the OECD’s Guidance on Financial Transactions |
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Steve Labrum, Baker McKenzie
Stefanie Perrella, Duff & Phelps
Amanda Pletz, NERA
Moderator: Loren Ponds, Miller Chevalier
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This panel will offer an overview and critical analysis of the OECD’s guidelines on intercompany financial transactions. After providing an overview of the relevant case law and legal considerations the panel will engage in an interactive conversation covering economic considerations related to implicit support drawn from the guidance. |
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| 12:30pm-1:00pm |
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Break |
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| 1:00pm-2:15pm ET |
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Panel 4: TP Debate (Economists vs Lawyers) |
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Topic 1: Who Drives the Bus in TP Engagements? Economists or Lawyers? |
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Topic 2: The Future of TP: Will our Grandchildren’s' Grandchildren live in a world where transfer pricing is still administered through the ALP? |
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Mark Bronson, Duff & Phelps
Thomas Linguanti, Morgan Lewis
Mike McDonald, EY
Elizabeth Stevens, Caplin Drysdale
Moderator: Karen Kirwan, CBE, IRS
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A team of lawyers will face off against a team of economists to debate two identified transfer pricing topics. |
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| Thursday, July 23 |
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| 11:00am-12:30pm ET |
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Panel 5: Update on OECD Pillar One Developments: Interview with Matt Andrew and Stewart Brant from the OECD |
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Matt Andrew, OECD
Stewart Brant, OECD
Moderators:
Donna McComber, Baker McKenzie Consulting LLC
Jill Weise, CBE, Duff & Phelps
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| 12:30pm -12:45pm ET |
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Closing Remarks |
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Jill Weise, CBE, Duff & Phelps
Perry Urken, Economics Partners |
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NOTE: The 2020 Transfer Pricing Symposium will be a live virtual event via the Zoom webinar platform. Playback recordings
will not be available.
In 2019, more than 250 Transfer Pricing professionals from nearly 60 firms and government agencies participated in the TPS.
The NABE Transfer Pricing Symposium qualifies for 6 IRS continuing education credit hours. Please send your PTIN # to [email protected] upon completion of the event in order to have your CE uploaded automatically.
If seeking CPE, CLE or other continuing education credits, you can request a Certificate of Completion from NABE by email before July 31. Certificates of Completion can be used to apply for continuing education credits with other certifying bodies.
Individuals who have earned the Certified Business Economist® (CBE) Certification are required to earn 30 continuing education credit hours every two years. The NABE Transfer Pricing Symposium qualifies for 6 continuing education credit hours. Please track your hours separately to be reported to NABE at the time of your renewal. CBEs are encouraged to track their credit hours on the CBE Continuing Education Form, which can be downloaded from www.NABE.com/CBE.
Sponsors
Interested in becoming a sponsor of the 2020 Transfer Pricing Symposium? Download the sponsorship packet or contact Tom Beers, NABE Executive Director, at [email protected].