Seminar October 20, 2021

Current Issues in Transfer Pricing Controversy

Event Detail
Richard L. Slowinski, E. Miller Williams, Jr., Stefanie E. Kavanagh
October 20, 2021
Alston & Bird
Washington, D.C.

Richard Slowinski, Miller Williams, and Stefanie Kavanagh lead a panel discussion in coordination with the United States Council for International Business (USCIB) on current issues in transfer pricing controversy. The panel included John Hughes, Director, Advance Pricing and Mutual Agreement Program, Internal Revenue Service and Rick Minor Vice President & International Tax Counsel with USCIB, and covered:

Global Transfer Pricing Outlook and U.S. Competent Authority Perspective

  • MAP and APA case overview, processing, and interim results
  • Current activities of OECD MAP Forum and connection to forthcoming work
  • Broad initiatives

Specific Issues and Challenges for U.S. Competent Authority

  • Operating status of APMA
  • MAP case dynamics
  • APA case dynamics

Going Forward and Taxpayer Interactions

  • Review of revenue procedures
  • What taxpayers can do to facilitate the MAP and APA processes

Update on U.S. Transfer Pricing Litigation Developments and Key Takeaways

Media Contacts
Nicholas Clarke
Communications Director
Phone: 212.210.1222

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