Henry Birnkrant and Sam Kaywood participated in this conference sponsored by the International Fiscal Association USA Branch. Henry Birnkrant was a featured speaker during the session, "Practical Transfer Pricing Strategies.” This panel discussed practical approaches to problems encountered by multinational corporations with their transfer pricing strategy and implementation.
Sam Kaywood moderated the session, "International M&A and Structuring." This panel reviewed several M&A related topics of interest, including what remains of inversions, planning tools to avoid "sandwich” problems (including the use of Section 304), problems in exiting foreign operations with dual consolidated losses and a few thought-provoking PLRs. The panel also discussed post-acquisition restructuring and reorganizations to ensure ongoing tax efficiency.
February 24-25, 2011