Learn what you need to know about Form 5472 including reporting guidelines and how to complete it properly.
Many companies who are required to prepare annual transfer pricing documentation and support for their intercompany transactions often do not understand that they need to do so, or what is needed in order to satisfy the US transfer pricing regulations. Additionally, these same companies likely do not understand the serious impacts transfer pricing has on their annual corporate income tax return, leaving them exposed to potentially large proposed tax adjustments and double taxation in the event of an IRS examination. This presentation will help attendees understand first what the transfer pricing rules and requirements are, and then how to intelligently comply while also keeping in mind any possible tax planning opportunities transfer pricing tends to present.
Learning Objectives
- You will be able to define the ‘arm’s length standard’ with respect to the US transfer pricing regulations, as well as the high-level US transfer pricing concepts associated.
- You will be able to describe the importance of transfer pricing with respect to mitigating a company’s tax exposure, while balancing possible tax planning opportunities.
- You will be able to discuss the various transfer pricing requirements needed to be in full compliance with the US transfer pricing requirements.
- You will be able to explain the impacts of incorrect transfer pricing on a company’s tax return and the risk exposure it creates.
Agenda
What Is Transfer Pricing?
- Definitions
- History
- Current Landscape
Why Is It Important?
- Eliminate Double Taxation
- Documentation and Agreement Requirements
- Efficient Tax Planning
How Is It Used?
- Transaction Buckets
- Cash Flow Planning
- Case Study Examples
Regulatory Requirements
- Documentation and Timing
- Foreign Divergences
- Customs Implications
Effects on Us Tax Return and Foreign Implications
- Forms 5471/5472
- Form 8858/8865
- FTC
Speakers
Yan Jiang,
Aprio- International Tax Consulting and Tax Director at Aprio
- Experience includes addressing the tax complexities associated with a variety of multinational business structures and cross-border transactions
- Extensive experience in international mergers and acquisitions, such as tax due diligence and restructuring
- Has assisted clients with various transactional projects dealing with international tax risk assessment, U.S. anti-deferral tax planning (CFC, Subpart F income, GILTI, foreign tax credit), and offshore cash expatriation
- Conducts both public and private seminars in the international tax area, recently delivering a series of international tax training sessions to a global financial institution, educating its bankers with the knowledge to navigate their clients’ cross-border tax issues
- M.B.A. degree and M.S. degree in Accounting, California State University, Los Angeles
Carl Budenski,
Aprio- Director and Co-leader of Aprio’s National Transfer Pricing Practice, also leading Aprio’s burgeoning Benelux practice
- Aprio’s transfer pricing expertise spans various global industries such as manufacturing, distribution, technology, and digital assets, with dedicated country groups for UK, Germany, Korea, China, Japan, and Australia/New Zealand
- Conducted numerous seminars and trainings on transfer pricing, and how it impacts businesses around the world, including a recent engagement for the Belgian Chamber of Commerce
- Author of numerous articles regarding transfer pricing
- M.S. degree in Finance and Economics, West Texas A&M University; B.B.A. degree in both Finance and Economics, magna cum laude, Drake University
Who Should Attend
This live webinar is designed for accountants, tax managers, CPAs, presidents, vice presidents, business owners and managers, CFOs, controllers, enrolled agents, CEOs, and finance directors.
