There are more transfer pricing adjustments at stake in the U.S. Tax Court than all other issues combined. Because transfer pricing is a popular way for a U.S. subsidiary to repatriate cash to a foreign parent, the IRS has an army of international examiners and economists ready to scrutinize a U.S. subsidiary'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. subsidiary may have with its foreign parent


• 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