CLE Course Details

Transfer Pricing for Multinationals: Practical Insights for Attorneys

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Price: $58
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  • Description

    Amongst the many challenging tax issues facing multinational companies today, transfer pricing is by far the most contentious and the most expensive. Faced with the competing requirements of the IRS and international tax authorities, many companies are struggling to navigate the issue.

    This informative CLE course will explain how attorneys can practically and properly identify and assess client global transfer pricing issues. The course will review the requirements of Section 6662 documentation standards, Section 482, and the OECD Transfer Pricing Guidelines. The course will include lessons learned from Coca Cola’s recent $9 billion tax court loss and other examples.

  • Instructor Bio

    Steven Cappellino

    Steve is a member of Varnum’s Tax Practice Team. He has substantial experience in federal, state and local taxation, in both planning and controversy. Steve previously held positions at both a large international accounting firm and the IRS Office of Chief Counsel. During his 12-year career with the IRS, Steve served as a Special Trial Attorney, handling large business tax cases of national significance. Prior to that, he was a Senior Attorney, advising IRS auditors, managers and executives on domestic and international issues, as well as tax procedure. As a CPA in the accounting firm, Steve provided compliance (federal, state and local), consulting and controversy services. He also has a background in sales, use and personal property taxes.

    Steve has extensive experience in the entire tax process, from audit inception through the appeals process and litigation. His technical experience spans corporate (both C and S corporations), partnership and individual taxpayer issues at the federal, state and local level. He also has experience in international taxation, including transfer pricing and inversions, as well as the judicial doctrines.

    Steve is also a member of Varnum’s Business and Corporate Services Team, advising both startups and mature businesses on issues including acquisitions, sales, mergers, succession planning, private equity and financing.

    Alexander Martin

    Alex Martin is Principal and Transfer Pricing Practice leader at KBKG, a nationwide tax specialty firm. KBKG was named one of the world’s leading transfer pricing consultancies by International Tax Review for 2021-2022.

    Alex has 24 years of full-time transfer pricing experience working in Washington, D.C.; Melbourne, Australia; and Detroit, Michigan over the course of his career. As a transfer pricing economist, Alex worked for a Big-4 firm for 12 years as a director, a top middle-market focused firm for six years as a principal, and four years as president of an independent transfer pricing consultancy. Alex has assisted companies in many industries addressing transfer pricing issues on a US and global basis, including transfer pricing documentation, audit defense, and Advance Pricing Agreements (APAs).

    Alex is best known for developing practical solutions for complicated transfer pricing issues, and he has published numerous articles based upon his time-tested transfer pricing strategies. He continues to be a sought-after transfer pricing speaker for CPA firms, attorneys, and other professional service firm networks. Alex has a Bachelor of Science in Economics from Tulane University and a Master’s Degree in Public Policy from the University of Michigan.