The Sixth Annual USD Transfer Pricing Symposium brings together top-level transfer pricing professionals, in a unique format. The symposium features live simulations led by highly experienced practitioners on transfer pricing dispute resolution and avoidance, including Competent Authority, APAs, IRS Appeals, Tax Court Litigation, and Federal Appellate Practice. In addition, the symposium includes peer group discussions and special panel topics, including corporate risk management, new "transparency" initiatives and provisions, economic analyses, and the Tax Cut and Jobs Act.
John Magee is chair of the program “The Tax Court Case – Part 1: The Fact Witnesses.” This session entails a moot-court presentation of transfer pricing litigation in the Tax Court. The proceedings, which involved a hypothetical fact pattern of XYZ Corp., included opening statements by the Petitioner (taxpayer) and the Respondent (the Commissioner), and the direct and cross examination of at least one material fact witness. The participants were also free to step out of their roles in order to comment freely upon their goals and objectives and key strategic considerations in connection with presenting and pursuing their case.
Sanford Stark is chair of the program “The Tax Court Case – Part 2: The Experts.” This session centers on the special considerations and procedures surrounding expert witness testimony. Since in the Tax Court, the report of the expert witness constitutes the direct testimony, this session focused primarily on effective cross-examination of the expert witness (or witnesses).
Participants also include tax attorneys Rod Donnelly, Wendy Abkin, Beth Williams, Michael Kummer, Dan Sosna, and Drew Allen.