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Tax Compliance: Transfer Pricing Regulation and Enforcement


Gain a better understanding of the basic principles of transfer pricing, including recent developments, tools, and current issues.

Many small-to medium-sized (SME) firms are not familiar with transfer pricing. Often, they are unaware of the penalty protections provided by contemporaneous transfer pricing documentation, unfamiliar with the requirements needed for documentation, underestimate expensive transfer pricing penalties, and are unfamiliar with the process of a transfer pricing audit. This topic provides an overview of transfer pricing concepts, transfer pricing documentation and recent court cases in the United States, a review of the IRS' transfer pricing examination process (TPEP) as well as best practices to ensure consistency between the transfer pricing documentation, intercompany pricing policies, and the tax return.



Kirk A. Hesser, MS

Kirk A. Hesser, MS

Cherry Bekaert

  • Managing director at Cherry Bekaert and serves as the National Leader of the Firm’s Global Transfer Pricing practice
  • With over 25 years of professional experience, he specializes in serving the transfer pricing and international tax needs of the firm’s multinational clients
  • Specific expertise includes transfer planning and savings strategies, global transfer pricing compliance documentation, transfer pricing controversy defense, and partnering with industry and outside legal advisors defending and structuring complex global business transactions
  • Industry background includes implementation of transfer pricing strategies for clients’ products, services and intangibles in the manufacturing, distribution, real estate, technology, transportation and logistics sectors
  • Also serves as a resource for THInc, the firm’s specialty practice that caters to the innovative needs of companies in the technology, health and life sciences, and industrial sectors
  • Prior to joining Cherry Bekaert, he held senior tax director and principal positions within the international tax practices of Big Four and national accounting and consulting firms
  • A well-respected and sought-after speaker on transfer pricing issues
  • M.S. and B.S. degrees in economics, Oklahoma State University
Adriano Suckow, BBA

Adriano Suckow, BBA

Cherry Bekaert

  • Senior Associate at Cherry Bekaert with almost four years of transfer pricing experience
  • Specific expertise includes transfer pricing planning, transfer pricing financial modeling, compliance and implementation of transfer pricing strategies
  • Prior to joining Cherry Bekaert, he was a transfer pricing analyst at Duff & Phelps (now known as Kroll Inc.) and an intern in Mercedes-Benz USA’s Vehicle Distribution and Logistics department
  • B.B.A degree, with an area concentration of Marketing and Strategy & Management Consulting, Emory University’s Goizueta Business School
Pamela Whitehead

Pamela Whitehead

Cherry Bekaert

  • Manager at Cherry Bekaert and leader of the International Compliance practice within the International Tax Group
  • 20+ years of international tax compliance experience
  • Prior to joining Cherry Bekaert, Pam was at Grant Thornton for 13 years, as well as several of the Big 4 firms prior to her time at GT
  • Expertise includes SubPart F, GILTI, FDII, BEAT, and OFL/ODL studies
  • Has worked closely with her transfer pricing colleagues over the years to ensure that the reporting in the tax return ties to the transfer pricing documentation

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