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