Why Attend?
In December, 2011, the Treasury issued final, temporary and proposed regulations on the transfer pricing implications and guidelines involving cost-sharing agreements (CSAs). The new regulations carry over a substantial portion of the 2009 temporary and proposed regulations (TD 9441) and adopt guidance included in the temporary regulation on the comparable uncontrolled transaction method. A CSA is an arrangement by which the participants agree to share the cost of developing one or more intangibles ("cost-sharing intangibles"). The regulations follow on the heels of several significant court cases such as Veritas Software Corp. v. Comm'r, 133 T.C. 297 (2009) and Xilinx Inc. v. Comm'r, 125 T.C. 37 (2005). The new CSA regulations play a key and critical role in the tax accounting process involving multi-national business operations in the development of intangibles and similar assets.
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What You Will Learn
Topics include:
Transfer pricing rules?& goals in general: An overview from 1,000 feet
Cost sharing agreements: What are they and when must they put into place?
How do CSAs reduce a companies overall income tax liability?
Recent case law on CSAs
An in-close look at the new regulations with insights provided by one of the key draftsmen of the regulations from the IRS Office of Chief Counsel
Review of the comparable uncontrolled transaction method, specified income method, specified residual profit-split method, the acquisition price method and the market capitalization method
Simple examples and illustrations adopted from principles in the regulations.
Impact on advance pricing agreements.
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Who Should Attend
Tax and business lawyers & related professionals.
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Planning Chair
?PLANNER & MODERATOR??
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Jerald David August , Fox Rothschild LLP, Philadelphia and West Palm Beach
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Faculty
Trevor Ackerman, Senior Manager/Director, KPMG LLP, Philadelphia
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Joseph L. Tobin, Senior Counsel, U.S. Department of the Treasury, I.R.S. Office of Chief Counsel, Washington, D.C.
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Program Schedule
All times eastern daylight
12:00 p.m. ??? Cost-Sharing Agreements: New Treasury Regulations - Part I:
??????????????????????????? -- Transfer pricing rules?& goals in general: An overview from 1,000 feet
??????????????????????????? -- Cost sharing agreements: What are they and when must they put into place?
??????????????????????????? -- How do CSAs reduce a companies overall income tax liability?
??????????????????????????? -- Recent case law on CSAs
? 1:15 p.m.????? Intermission
? 1:30 p.m. ???? Cost-Sharing Agreements: New Treasury Regulations - Part II:
??????????????????????????? -- An in-close look at the new regulations with insights provided by one of the key draftsmen of the regulations from the IRS Office of Chief Counsel
??????????????????????????? -- Review of the comparable uncontrolled transaction method, specified income method, specified residual profit-split method, the acquisition price?method ????????????????????????? ? ??? and the market capitalization method
??????????????????????????? -- Simple examples and illustrations adopted from principles in the regulations.
??????????????????????????? -- Impact on advance pricing agreements.
? 3:00 p.m.????? Q&A Session
? 3:15 p.m.????? Adjournment
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Email questions before or during the program to vquestions@ali-aba.org
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Total 60-minute hours of instruction: 3.0; total 50-minute hours: 3.6
Educational Objective: "This program is designed to inform tax practitioners already familiar with section 482 and CSAs in general on the important aspects of the new regulations. The program also should be attended by lawyers and accountants who want to gain greater knowledge and proficiency in this area of the tax law."
Level of Instruction: Intermediate to Advanced
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Times
Eastern 12:00 pm ? 3:15 pm
Central 11:00 am ?2:15 pm
Mountain 10:00 am ? 1:15 pm
Pacific & Arizona 9:00 am ? 12:15 pm
Alaska 8:00 am ? 11:15 am
Hawaii 6:00 am ? 9:15 am
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Tuition for this Video Webcast is $299.00.
Tuition for the webcast includes a set of electronic course materials, access to the webcast and online access to the archived program after the webcast.
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If you prefer not to order online you can order by Phone or Fax:
Phone: 800-CLE-NEWS (800-253-6397) (Reference Course Code: VCT0312)
PDF Order form - FAX: 215-243-1664 (Reference Course Code: VCT0312)
Source: http://ali-aba.org/VCT0312
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