There are more transfer pricing adjustments at stake in the U.S. Tax Court than all other issues combined. Due to the special transfer pricing penalty, the IRS has an army of international examiners and economists ready to scrutinize a U.S. company's transfer pricing. This program will teach you the tools necessary to defend your client's transfer pricing.
 
Learning Objectives:

• Determine all the intercompany transactions that a U.S. company may have with its foreign subsidiary


• Identify the different transfer pricing methods from which the parties must choose the best method


• Recognize how to prepare the transfer pricing documentation to avoid penalties and prevent adjustments