BorderCrossings ... with Ernst & Young's transfer pricing and tax professionals
A monthly webcast series addressing US-Canada transfer pricing and related multinational tax issues
Transfer pricing touches nearly every area of your multinational operations, making it one of your key tax challenges and concerns. Increasingly well-staffed tax authorities are applying more sophisticated and sweeping transfer pricing tools, placing greater demands on you to document and defend your transfer pricing in more and more countries. To help you stay informed and able to adopt a more proactive stance in developing and defending your transfer pricing policies and practices, Ernst & Young is pleased to bring you this third installment of BorderCrossings - our monthly webcast series devoted to transfer pricing and related tax issues.
APA update: lessons learned and keys to success
The Advance Pricing Agreement (APA) program is 20 years old. What are the lessons learned and keys to a successful resolution of an APA? What is the impact of arbitration on APAs?
APAs have long been considered by both multinationals enterprises and tax administrations alike as the preferred avenue of recourse to resolve recurring, contentious, international tax disputes. Interest in the APA program has remained strong due to enhanced enforcement efforts by the governments and the desire to minimize uncertain tax positions.
The speakers will discuss:
- The evolution of the APA program
- Have the governments changed their approach?
- When does an APA make sense?
- The short-term and long-term benefits
- Unilateral and bilateral APAs as part of global strategy
- Arbitration: the impact, procedures for APAs and experiences to date
- Impact of IRS APA staffing changes on cases
- The future of APAs
During this live, interactive webcast, you will have the opportunity to ask questions through the website, and the panelists will answer as many of your questions as time permits.
This program will be of interest to vice presidents/directors of tax/international tax/transfer pricing, directors of finance, CFOs, international tax managers and tax accountants looking for the latest practical information and planning ideas to support their global business initiatives. We hope you will be able to join us.
Paul Mulvihill, Ernst & Young LLP (Canada), Transfer Pricing Services, Ottawa
Steven Wrappe, Ernst & Young LLP (US), Transfer Pricing Services, Washington, D.C.
Fred O'Riordan, Ernst & Young LLP (Canada), National Advisor Tax Services, Ottawa
Register now for the next upcoming BorderCrossings webcast:
24 May 2011 - Financial transactions: not just for banks