| Date: |
2/04/2006 |
| Start Time: |
10:30 AM |
| End Time: |
12:30 PM |
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Transfer Pricing Chair:
Foreign Acticities of US Taxpayers Chair: |
Steven Wrappe, Deloitte & Touche LLP, Washington, DC
Peter H. Blessing, Sherman & Sterling LLP, New York, NY
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| Agenda: |
10:30am Proposed Cost Sharing Regulations: An In-Depth Analysis from Legal and Economic Perspective. Treasury and the IRS have issued proposed regulations concerning reallocations under section 482 for certain cost-sharing arrangements. The proposed regulations would replace the existing 1995 cost-sharing regulations, which govern certain qualified cost sharing arrangements. Substantial comments have been provided concerning these regulations. This program will consider the proposed regulations from legal, accounting, and economic perspectives. The panel includes practitioners with substantial experience in cost sharing area, and also includes principal drafters and architects of the proposals. Moderator: David N. Bowen, Mayer, Brown, Rowe & Maw,Washington, DC. Panelists: Robert T. Cole,Alston & Bird LLP,Washington, DC; Alan W. Granwell, Ivins, Phillips & Barker,Washington, DC; Steve A. Musher, Internal Revenue Service,Washington, DC; Michael MacDonald, Department of Treasury, Washington, DC; Irving H. Plotkin,PriceWaterhouseCoopers, Boston, MA. |
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