The Tax Trifecta Plus: Transfer Pricing, Audits, M&A & International Update

The Morgan Lewis tax team will join the Tax Executives Institute’s Baltimore/Washington Chapter in hosting a fall CPE event in the firm’s Washington, DC office. Panelists will examine recent updates in transfer pricing, international tax and mergers and acquisitions (M&A), and audit management.

TEI is a member-based organization dedicated to the professional needs of the worldwide in-house tax community, working to educate, connect, and advocate on all aspects of business taxation. The institute possesses unrivaled practical experience and is uniquely positioned to help organizations navigate the ever-changing global tax environment. This event is a part of our firm’s longstanding engagement with the organization.

Latest and Greatest M&A Tax Developments
Speakers: Matthew Schnall and Jared Sanders

Discussion topics:

• Recent trends in transaction consideration, structure, and documentation with significant tax implications
• Impact of recent guidance from the US Department of the Treasury and the Internal Revenue Service

International Tax Update
Speakers: Bart Bassett and Scott Farmer

Discussion topics:

• Key legislative, regulatory, and policy updates shaping multinational tax planning and compliance
• Best practices for anticipating and mitigating risks from evolving international tax regulation

Managing Third-Party Information Requests in Audits, Courts, and Internationally
Speakers: Alex Sadler, Doug Norton, and Jamie Steele

Discussion topics:

• Practical considerations when dealing with third-party requests from both the perspective of the taxpayer at issue and the third party
• The response to each request may be different depending on the phase of the controversy – whether conducted during an audit, in active litigation, or involving the exchange of information through an international treaty
• Rules concerning information requests to third parties by the IRS and foreign tax authorities and strategies surrounding responding (and contesting) each of the various types of requests from taxing authorities

Can Economic Substance and Transfer Pricing Peacefully Co-Exist?
Speakers: Drew Cummings and Tom Linguanti

Discussion topics:

• In recent years, tax authorities have been asserting both economic substance and transfer pricing adjustments against the same covered transactions; how are taxpayers and the courts supposed to handle these potentially mutually exclusive tax authority positions?
• Interaction between these positions and factors to consider in responding during audits and litigation

CPE Credit: See event website for more information.