Ronald Reagan Building and International Trade Center
Richard Slowinski served as a program co-chair for transfer pricing and moderated the panel “New World for Resolving Transfer Pricing Disputes” at the Federal Bar Association’s 43rd Annual Tax Law Conference The panel discussed how to resolve transfer pricing disputes in light of enforcement trends, IRS campaigns, recent APMA and case-law developments, and OECD BEPS project considerations. The panel discussed:
- How the IRS is approaching transfer pricing enforcement, including identifying issues, executing IRS campaigns, and LB&I directives.
- Update on transfer pricing litigation developments, potential effect on intercompany transactions, and identifying future trends.
- What IRS APMA developments mean for taxpayers.
- Changes in administrative and policy orientations of the Canada Revenue Agency regarding transfer pricing in Canada.
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