U.S. Transfer Pricing and Global BEPS

Focuses on U.S. transfer pricing and global base erosion and profit shifting (BEPS).

• Identify fundamental transfer pricing adjustments and their impact on related international tax topics.
• Recognize the relationship between transfer pricing and certain areas of international tax.
• Determine when IRC Section 482 applies.
• Identify the accepted transfer pricing methods and recognize when each is appropriate to use.
• Recall how transfer pricing documentation can reduce penalties.
• Recognize the base erosion and profit shifting (BEPS) initiatives and their relationship to U.S. and global transfer pricing.

• Section 482
• Transfer pricing methods
• Levels of documentation
• BEPS overview
• BEPS relationship to U.S. and global transfer pricing