PPT-Current Trend of IRS Transfer Pricing Practices

November 8 2013 Index What is Transfer Pricing Basics of Transfer Pricing Why is it important US Transfer pricing rules Common Intercompany Transactions Transfer Pricing Disclosures amp Penalties. Handbook for the Oil . & Gas Industry. August 2012. All materials, content and forms contained in this handbook are the intellectual property of TPA, and may not be copied, reproduced, distributed or displayed without TPA's express written permission.. Taxpayer Advocate Service . Research & Analysis. June 2015. Focus. Taxpayer Delinquency Account (TDA) liabilities.. Individual Master File. Collection statute (generally 10 years). Background. Over 50 percent of the IRS Individual Master File (IMF) TDA inventory has been in the function assigned the delinquency for at least 10 months.. Industry . Benchmarking . for . select . Industries. Bhupendra Kothari. Villy Dhabhar. 28 October 2012. Contents. Sector Based Transfer . Pricing . Policy – . Manufacturing Sector. Distribution Sector. Special . Agent Susan Prine. IRS-CI’s Mission Statement. . Criminal Investigation serves the American public by investigating potential criminal violations of the Internal Revenue Code and related financial crimes in a manner that fosters confidence in the tax system and compliance with the law.  . John Taylor. North Carolina State University. Session Etiquette. Please turn off all cell phones. . Please keep side conversations to a minimum. . If you must leave during the presentation, please do so as quietly as possible.. Austrian Branch Report. Vienna, 15 March 2017. Dr. . . Andrea Lahodny. Partner – Transfer Pricing. Dr. . Raffaele . Petruzzi. , LL.M. .. Managing Director, WU Transfer Pricing Center. Transfer . Pricing. Questions. David Ward. How big is the community working on IRS?. What about my Use Case?. What about my favorite Encoding?. What about . NetConf. /Yang?. How big is the IRS community?. 408 members on list. Product comparability criteria are difficult to meet in our industry. IMPORT TRANSACTIONS. EXPORT TRANSACTIONS. CUP/PIC. COST 20%. RPM / PRL . (40% GM for Pharma). CUP/PIC. COST . 15%. RPM / PRL . (15%PVA/PVV30%). Presented by Glen MacMillan – Adams & Miles LLP. General background. Rules and Regulations. Penalties. Contemporaneous Documentation. Transfer Pricing Methods. IRS. Compliance and Enforcement. Compare the alternative pricing strategies and explain when each strategy is most . appropriate.. Describe how prices are . quoted.. Identify the various pricing policy decisions marketers must . make.. November 8, 2013. Index . What is Transfer Pricing?. Basics of Transfer Pricing – Why is it important. ?. U.S. Transfer . pricing . rules . Common Intercompany Transactions. Transfer Pricing Disclosures & Penalties. David Fender. Cost plus …. Willingness to pay…. Possible pricing strategies. Identifying and adhering to both short-run and long-run pricing strategies. Maximizing profits. Maintaining or gaining market share. They Could Cross!. August 20, 2015. UTA. Mary K. Thomas. Weaver, LLP. 972-448-6965. Slide . 1. Texas Exports. . Brazil. Canada. Mexico. 2011. 10.1. 22.1. 87.2. 2012. 10.0. 23.9. 94.4. 2013. 10.9. 26.1. Into A Winning Formula . Damon V. Pike/Anna Zajac - BDO USA, LLP. Wendy Everett/Keith Anderson - Schaeffler Group, USA, Inc.. . Agenda. Basics of Transfer Pricing. Customs Valuation Overview. Related Party Pricing – “Circumstances of Sales”.