Patricia Lewis to Discuss APAs at National Conference

06.21.2010

Date of Session: June 22, 2010

Session Description: The IRS has considerably stepped up its audit activity in the transfer pricing arena, where adjustments can be huge and penalties severe. Companies of all sizes need to take precautions, either by negotiating advance pricing agreements (APA) with the IRS or by conducting or commissioning transfer-pricing reviews from external professionals. The APA process is designed to resolve actual or potential transfer pricing disputes, largely prospectively, in a principled, cooperative manner. Although an APA is the most secure way to attain certainty against transfer pricing exposure and penalties, the process of obtaining an APA can be complex and lengthy.

    • Considerations in choosing APA route 
    • Special features of transfer pricing methods for APAs
    • APA process requirements, dynamics and tips
    • Critical assumptions used in APAs
    • Benefits and challenges of bilateral APAs
    • Specific industry and emerging markets considerations

Speaker: Patricia Gimbel Lewis, Member, Caplin & Drysdale, Chartered

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