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 arm's 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.
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.
Jinkan has twelve years of experience in transfer pricing consisting of two years of academic study and ten years of professional experience. Jinkan has specialized in transfer pricing while pursuing a graduate degree in economics under the guidance of a prominent professor in the field. After graduating, Jinkan worked as a transfer pricing analyst with a prominent media and entertainment company in New York City with presence in more than 50 countries gaining valuable in-house experience. Subsequently, Jinkan worked as a consultant with a mid-size tax consulting firm in New York City. Jinkan’s expertise includes planning, documentation, audit support, and operational process improvement with experience working with leading multinational firms in manufacturing, distribution, technology, telecommunication, medical devices, and services industries. In addition, Jinkan Khatadia has extensive experience in managing transfer pricing compliance process for a Fortune 500 multinational company in the manufacturing and distribution of prestigious cosmetics products industry, and for a multi-billion dollar private company in the sports footwear and apparel industry.