Conferences and Speeches
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