Gain a better understand cost sharing arrangements in the current legal and tax environment.
Cost-sharing arrangements are one of the common sources of transfer pricing controversies. Recent Tax Court cases have called into question the validity of certain provisions of the cost-sharing regulations. This topic will walk through the current cost-sharing regulations under the U.S. transfer pricing guidelines in detail, identify the provisions that have been called into question, and discuss impacts of the OECD BEPS initiatives on the structure of cost-sharing arrangements. This course is beneficial for individuals who are new to cost-sharing arrangements or who want to understand cost-sharing arrangements in the current legal and tax environment.
Agenda
Faculty
Mumi Hemrajani
DLA Piper LLP (US)
- International Tax Attorney at DLA Piper LLP
- Concentrates in international tax planning, transfer pricing, and post-merger integration of IP and legal entities
- Prior to joining DLA Piper, served as a General Attorney in the Office of the Associate Chief Counsel International at the Internal Revenue Service providing legal advice on cases involving transfers of intangibles offshore, buy-in payments, and cost-sharing arrangements
- Assisted in the publication of the section 482 final cost-sharing regulations (TD 9568) in 2011 and served as the drafting attorney on related bullet regulations (TD 9569 and TD 9630) in 2012
- Contact Information: 1 202 799 4371. E-mail: [email protected]
Wei Wang
DLA Piper LLP (US)
- Managing Director at DLA Piper LLP
- Concentrates in transfer pricing, including intercompany policy design and implementation, tax restructurings and supply chain optimization, IP migration, and general compliance and documentation
- Charter Financial Analyst
- M.A. in International Economics and Finance, Brandeis International Business School
- Can be contacted at 650-833-2125 or [email protected]
Madhura Maitra
DLA Piper LLP
- Senior Managing Economist at DLA Piper LLP
- Assists multinationals in transfer pricing and tax planning matters in various industries
- Extensive experience in building complex models related to cost-sharing arrangements as well as valuation of intangibles in the context of cost-sharing arrangements
- Received Ph.D. in Economics (Specialization in International Trade) from Columbia University
- Authored articles related to international trade and transfer pricing
- Contact information: 1 650 833 2463. E-mail: [email protected]
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