TEI Silicon Valley Chapter Program: Transfer Pricing: Controversy, Compliance, BEPS, & Planning

Rod Donnelly, Sanford Stark, and Bart Bassett spoke at TEI Silicon Valley on “Transfer Pricing: Controversy, Compliance, BEPS, & Planning” to an audience of 80 in-house tax professionals. They teamed with three PWC partners for the presentation.  

Topics included the following:

• Final § 367 and Temporary § 482 regulations
• BEPS Actions 8-10 vs. § 482
• Documentation and compliance requirements
• OECD attribution of profits to a PE
• Treaty considerations (including Multilateral Instrument)
• Recent audit experience
• Litigated cases and consequences for taxpayers