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Figuring Out: Transfer Pricing in a Two-Standard Tax World | Podcast #62 0.5 Credit

Figuring Out: Transfer Pricing in a Two-Standard Tax World | Podcast #62 0.5 Credit

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Learning Objectives

  • Explain why transfer pricing directly affects global tax risk and cash outcomes.
  • Compare IRS and OECD transfer pricing frameworks and their core structural differences.
  • Identify key compliance challenges under dual IRS and OECD transfer pricing systems.
  • Analyze how OECD Pillar Two interacts with existing transfer pricing strategies.
  • Evaluate practical steps firms can take to prepare for upcoming global tax changes.

Course Overview

Is transfer pricing just a technical tax exercise, or a strategic lever that can move millions across borders? In a world where global businesses operate under two competing standards, the IRS on one side and the OECD on the other, transfer pricing has become a high-stake balancing act. This Episode digs into why transfer pricing matters now more than ever, how historical policy choices created today’s split frameworks, and what happens when companies misjudge the line between compliance and strategy. From audit exposure to real cash tax outcomes, the discussion grounds abstract rules in practical consequences firms face every day.

Carl Budenski, Tax Partner and Transfer Pricing Leader at Aprio, brings a practitioner’s lens to this complex terrain. Drawing from decades of advising multinational and mid-market companies, he explains how U.S. and Organisation for Economic Co-operation and Development (OECD) transfer pricing regimes evolved along different philosophical paths, and why that divergence creates friction for modern businesses. Carl also unpacks how companies document, defend, and sometimes rethink their pricing models when operating across jurisdictions, especially as new global tax initiatives approach.

Major Topics:

  • Transfer pricing business impact
  • IRS versus OECD evolution
  • Dual framework compliance challenges
  • OECD Pillar Two overview
  • Pillar Two readiness strategy
  • Future global tax trends
  • Key takeaways and actions

As the conversation turns to OECD Pillar Two and its expected rollout in 2026, listeners gain clarity on what is real, what is overhyped, and who should be paying attention now. This CE Episode offers a clear, practical roadmap for tax leaders, CFOs, and advisors navigating a two-standard world, and challenges firms to think beyond compliance toward long term alignment and resilience.

For more IRS CE Courses, Click here.

On Demand Credits for All Qualifications

License details Credits Status
Taxes for Certified Public Accountants (CPA-US) 0.5 CPE Approved
Taxes for Delaware Licensed Public Accountant (DE-LPA) 0.5 CPE Approved
Taxes for Iowa Licensed Public Accountant (IA-LPA) 0.5 CPE Approved
Taxes for Maine Licensed Public Accountant (ME-LPA) 0.5 CPE Approved

Additional Information

Credits

0.5

Course Level

Basic

Instructional Method

QAS Self Study

Group Internet Based

Pre-requisites

None

Advance Preparation

None

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MY-CPE LLC is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org.

About Experts

Carl Budenski

Carl Budenski

Partner, Aprio

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Carl leads Aprio's Transfer Pricing Practice as a Tax Partner in the International Tax team, advising multinationals on complex compliance and global strategies. With proven success, including $1M annual U.S. tax savings for clients, he excels in financial analysis, risk management, and process improvements. A thought leader, Carl speaks at conferences and authors articles on transfer pricing, drawing from five years at RSM.


Passionate about business growth, he collaborates with executives to tackle tax challenges proactively. His high-performance history ensures tailored solutions for domestic and international firms, blending expertise with client-focused mentorship.

Saulsony

Saul Sony

Director, MYCPE ONE

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As Director – Partnerships, Content Strategy, and M&A Advisory, I drive growth at the intersection of education, strategic alliances, and transaction advisory within accounting and professional services.

I partner with thought leaders, firms, and content creators to build high-impact collaborations and deliver compliance-ready content that helps professionals educate, influence, and scale on the MY-CPE ONE platform. I work closely with CPA and accounting firm owners to support MYCPE ONE's inorganic growth strategy identifying the right partners and aligning them toward shared goals.

In the M&A and advisory space, I work closely with private equity firms, accounting leaders, and advisors to create educational resources that support practice growth, succession planning, and deal execution. Through podcasts, webinars, and curated learning experiences, my goal is to enable smarter dealmaking and build stronger professional alignment. I work with CPA and Accounting Firm owners to collectively help MYCPE ONE's inorganic growth plans.

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MY-CPE LLC courses are accepted for continuing education credit by various professional certification programs, including NASBA, IRS, CFP Board, and HRCI. MY-CPE LLC is also recognized by SHRM to offer Professional Development Credits (PDCs) for SHRM-CP® and SHRM-SCP® recertification activities.

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To maintain compliance, you must follow the guidelines set by NASBA and other regulatory bodies, which include completing the course within the specified timeframe, passing the assessments, and keeping accurate records of your learning activities.

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Figuring Out: Transfer Pricing in a Two-Standard Tax World | Podcast #62

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