CPA - medium firm
Other
Transfer pricing is frequently discussed in tax circles, often associated with large tax adjustment and penalties. The cases reported in the tax press provide little enlightenment on the transfer pricing rules or application. This course will explain the fundamentals of transfer pricing, including the arms length standard, the best method, comparability, and the arm’s length range. Next, it will demonstrate how those rules apply to common transactions. Finally, it will address the US transfer pricing-specific penalty rules and their application in common scenarios. Participants should achieve an understanding of the basic application of transfer pricing rules, consequences, and ways to avoid transfer pricing pitfalls.
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General US rules and transfer pricing concepts
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Application to tangible, intangibles and services transactions
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Transfer pricing penalties and application
Steven Wrappe
Grant Thornton, LLP
National Leader for Transfer Pricing Dispute Resolution
steven.wrappe@us.gt.com
(202) 533-3077
Steve Wrappe is Grant Thornton LLP's Transfer Pricing Technical Leader in its Washington National Tax Office. Steve has over 25 years of client and government experience in transfer pricing and tax controversy. Prior to Grant Thornton, Steve led the transfer pricing controversy practice at other Big Four firms and was a partner with a global law firm. He has transfer pricing experience across all industries and is one of the most experienced negotiators of transfer pricing controversy. Steve has negotiated well over 150 advance pricing agreements (APAs) and mutual agreement procedures and negotiated the first APA coordinated with a Customs ruling. Steve has also been involved in international tax planning and tax provision work for multinational corporations.
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