February 15, 2023

Avoiding a Dispute or Finding a Path to Resolution


Join Mayer Brown and Economics Partners for the second of our two-part series taking an in-depth look at the current state of transfer pricing issues.

In our prior session, we focused on managing an IRS examination involving transfer pricing issues and described how careful preparation can lead to successful outcomes. But what happens when it doesn’t? Our second presentation tackles that question. We will discuss ways to avoid or resolve transfer pricing disputes. Along the way, we will deal with questions like:

  • How can I use the APA or ICAP process proactively to achieve my transfer pricing goals?
  • Is the traditional IRS Appeals forum the best path for me?
  • What about all of these other resolution mechanisms I’ve heard about, like MAP and Simultaneous Appeals? What are the pros and cons of those?
  • And what are the relative strengths of transaction and profit-based transfer pricing analyses in these processes?

Lurking behind all of these options, of course, is the specter of transfer pricing litigation, and we will cover some of the basic considerations there, too. Whatever path or paths you pursue, it’s important to have a firm understanding on the front end of what the timetable could look like, as well as the types of economist and other resources both you and the IRS will bring to bear.

Additional Speakers

Perry Urken
Economics Partners

Brian Vincent
Economics Partners

Approval for CLE credit is pending.

United States
12:30 p.m. – 2:00 p.m. ET
11:30 a.m. – 1:00 p.m. CT
10:30 a.m. – 12:00 p.m. MT
9:30 a.m. – 11:00 a.m. PT

5:30 p.m. – 7:00 p.m. GMT
4:30 p.m. – 6:00 p.m. CET

For additional information or to register, please contact Shilpa Patel at spatel@mayerbrown.com or +1 312 701 8487.

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