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Transfer Pricing

  • Accountant
  • AFSP
  • CRTP
  • CPA (US)
  • EA
  • ORTP
  • MRTP
  • CFIRS
  • CWS

Published: January, 2022

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  • Course Description
  • Course Qualification
  • Presenter
  • FAQ

Course Description

Overview

  • Comparability
    5 mins
  • Conceptual framework
    26 mins
  • Transfer pricing methods - CUP
    31 mins
  • Transfer pricing methods - Profit split
    46 mins
  • Intangibles - Commensurate with income
    62 mins
  • Serviec - Allocation of costs
    84 mins

Course Description

Transfer pricing is frequently discussed in tax circles, often associated with large tax adjustment and penalties. The cases reported in the tax press provide little enlightenment on the transfer pricing rules or application

Multinational Enterprises (MNEs) use transfer pricing for internal resource allocation, planning, profit maximization, and tax minimization.

Governments want an MNE’s transfer prices to adequately reflect arm’s length or market value so the appropriate amount of tax is paid within a Government’s jurisdiction. Transfer pricing concerns the theory, practice, strategy, and taxation of intra-firm trade among affiliated entities of the MNE.

Transfer pricing is important for the following reasons: maximizing corporate profits, monitoring segmental (department, division, subsidiary) performance, establishing corporate control over cash and income flows, advancing strategic objectives, and reducing the overall corporate tax burden and the average tax rate.

Transfer pricing is a multidisciplinary discipline involving economics, accounting, corporate taxation, international business, and the law.

This CPE course is a combination of theory and actual practice.


Note:- William Seeger moved on from this world. With sadness in our hearts, we find solace in knowing that he’s in a better place.

Learning Objectives

  • To discuss the basic workings of the international tax and transfer pricing regimes.
  • To analyze, evaluate, and understand divisional structures of business enterprises about legal entity structures. 
  • To investigate the various methods of determining transfer prices about profit maximization.
  • To discuss the Arm’s Length Principle as a guide to market-based outcomes. 
  • To describe the concept of comparability. 
  • To explain the circumstances under which the various transfer pricing tax methods are arm’s length from a tax perspective. 
  • To discuss the strategic differences in exploiting intellectual property with cost-sharing or licensing. 
  • To analyze transfer pricing approaches to valuing services, loans, leases, and tangible property.
  • To review Dispute Resolution procedures in international transfer pricing. 
  • To discuss income shifting about corporate tax planning.

Recommended For

  • This CPE webinar is recommended for Tax partners, managers, and staff, CPAs, enrolled agents, tax return preparers, tax attorneys, and other practitioners who desire to help their clients with the transfer pricing strategies.

Who Should Attend?

  • Annual Filing Season Program
  • Bookkeepers & Accountants & Tax Preparers
  • California Registered Tax Professional
  • Certified Practicing Accountant
  • CPA (Industry)
  • CPA - Large Firm
  • CPA - Small Firm
  • CPA in Business
  • Enrolled Agent
  • Maryland Tax Preparers
  • Oregon Tax Preparers
  • Tax Accountant (Industry)
  • Tax Attorney
  • Tax Firm
  • Tax Managers
  • Tax Preparer
  • Tax Professionals
  • Tax Pros
  • Young CPA

Course Qualification

Webinar Qualifies For

  • 2 CPE Credit of Taxes for Certified Public Accountants (CPA-US)
  • 2 CE Credit of Federal tax-related matters for Enrolled Agents (EA) (Approval No. GEHNZ-T-00775-21-S)
  • 2 CE Credit of Federal tax-related matters for Annual Filing Season Program (AFSP)
  • 2 CE Credit of Federal tax-related matters for California Registered Tax Preparers (CRTP) (Approval No. 6273-CE-0718)
  • 2 CE Credit of Federal tax-related matters for Oregon Registered Tax Preparers (ORTP) (Approval No. GEHNZ-T-00775-21-S)
  • 2 CE Credit of Federal tax-related matters for Maryland Tax Preparer (MRTP) (Approval No. GEHNZ-T-00775-21-S)
  • 2 CE Credit for Certified Fiduciary & Investment Risk Specialist (CFIRS)
  • 2 CE Credit for Certified Wealth Strategist (CWS)
  • 2 General Credit of Taxes for Accountant/Bookkeeper/Tax Professionals

Additional details

  • Course Level :
    Basic
  • Credits :
    2
  • Instructional Method :
    QAS Self Study
  • Pre-requisites :
    None
  • Advance Preparation :
    None

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MY-CPE LLC, 1600 Highway 6 south, suite 250, sugar land, TX, 77478

MY-CPE LLC (Sponsor Id#: GEHNZ) has entered into an agreement with the Internal Revenue Service, to meet the requirements of 31 Code of Federal Regulations, section 10.6(g), covering maintenance of attendance records, retention of program outlines, qualifications of instructors, and length of class hours. This agreement does not constitute an endorsement by the IRS as to the quality of the program or its contribution to the professional competence of the enrolled individual. Credit earned by attendees with a PTIN will be reported directly to the IRS as required of all providers. To ensure your CPE hours are reported, update your profile in My Account to include your PTIN number. Please note: IRS CE is only mandatory for EAs and ERPAs. For all other tax return preparers, CE is voluntary.

NASBA APPROVED

MY-CPE LLC, 1600 Highway 6 south, suite 250, sugar land, TX, 77478

MY-CPE LLC (Sponsor Id#: 143597) 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.

CTEC APPROVED

MY-CPE LLC, 1600 Highway 6 south, suite 250, sugar land, TX, 77478

MY-CPE LLC (Sponsor ID# : 6273) has been approved by the California Tax Education Council to offer continuing education courses that count as credit towards the annual “continuing education” requirement imposed by the State of California for CTEC Registered Tax Preparers. A listing of additional requirements to register as a tax preparer may be obtained by contacting CTEC at P.O. Box 2890, Sacramento, CA, 95812-2890, toll-free by phone at (877) 850-2832, or on the Internet at www.ctec.org.

Presenter

About Presenter

William Seeger

President, QuantEcon Consulting

Dr. Seeger is currently a Clinical Professor of Economics at the University of Texas at Arlington, College of Business Administration, and President of Quantecon Consulting, an Economic consulting firm.  The focus of his academic research is Transfer Pricing and International Tax issues. Upon his retirement in October 2014, Dr. Seeger was a Principal in KPMG’s Global Transfer Pricing Services practice. He was practice leader, Economic and Valuation Services, for the Dallas, Houston and Denver Business Units and a senior economist and Southwest area lead for KPMG’s Economic Consulting Practice. Dr. Seeger has twenty years of experience in public accounting and three years’ experience with the Internal Revenue Service as an Industry Economist in the Comprehensive Examination Program. 

In his public accounting career, Dr Seeger specialized in economic and tax issues related to tax efficient structuring of the operations of multinational organizations. He has advised clients on the Transfer Pricing economics related to intercompany financing, deferral, intangible planning, services, shared cost allocations, and operational price setting. While at KPMG, Dr. Seeger led Transfer Pricing teams as part of KPMG's financial statement audits of clients related to Fin 48 matters, assisted in Transfer Pricing Dispute Resolution, helped clients with negotiating and establishing their Advance Pricing Agreements, worked with KPMG's Mergers and Acquisitions teams on Transfer Pricing exposures of potential target acquisitions, and served as part of KPMG's Quality review team finalizing TP reports for release to clients.

As the market leader for KPMG in the Dallas/Denver Business unit, Dr. Seeger had oversight in the areas of Oil and Gas, Engineering and Construction, Consumer and Industrial Business, and Financial Services. He was the Southwest area practice leader for Transfer Pricing services and Economic Consulting Services, the Global market leader for Energy and Natural Resources in the areas of oil and gas, chemicals, utilities, engineering and construction, and mining and forestry, and the National Transfer Pricing leader for the Engineering, Construction, and Procurement industry market segment.

Dr. Seeger has a PhD and MA in Political Economy from the University of Texas at Dallas, with specializations in Industrial Regulation and Econometrics, and a BA in Economics from the University of Notre Dame, with a concentration in Quantitative Economics. He is currently a candidate for a Master’s degree in Jurisprudence in International Taxation from the Texas A&M University Law School.  

About Company

QuantEcon Consulting

quanteconconsulting.com/

Economic Consulting Services including Transfer Pricing / Dispute Resolution / International Trade / Policy & Taxation / Forensic Investigation / Public Speaking for mid to large size businesses.

We are a team of diverse professionals who recognize that success in business depends upon a multidisciplinary approach to problems. Problems and their solutions are never one dimensional;  as such our diverse skills provide a unique platform upon which all facets of a challenging problem can be assessed and solutions discerned and derived. 

The first thing we'll do for you is listen. We need to understand your perspective and point of view on the challenges you face. Second, we become experts on your business model and your position in the marketplace. Thirdly, we provide value by providing the right solution that comports with your facts and unique circumstances. Finally, we don't fold up our consulting tent and walk away; instead we partner with you on the implementation of our proposed solution.

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Ratings and Review

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SP

Sameer Paddalwar, CPA (US)

May 6th, 2022

Overall its good to learn the TP Concepts

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