| Agenda: |
8:30am Tax Provisions and Transfer Pricing: Implications of FAS 109 and FAS 5 on Intercompany Transactions. Overview of the financial accounting principles governing uncertain tax positions as those principles apply to transfer pricing, including FASB’s recent Exposure Draft and current thinking on the subject. The program includes a discussion of practical implications for establishing and removing tax reserves for transfer pricing transactions. Moderator: James Wisniewski, Ernst & Young, Chicago, IL. Panelist: Mark Weisz, Nortel Networks, Richardson, TX.
9:30am Foreign Reaction to Recent IRS Proposed Changes to Transfer Pricing Regulations (Cost Sharing, Services and Intangibles). This panel will discuss Canadian, Asian and European reactions from the perspectives of both practitioners and tax authorities to the IRS’s recently proposed transfer pricing regulations. Moderator: Thomas Akin, McCarthy Tetrault LLP, Toronto, Canada. Panelists: Ken Okawara, Ernst & Young, Tokyo, Japan; Shin Nihon, Ernst & Young, Tokyo, Japan; Monique van Herksen, Baker & McKenzie, Amsterdam, Netherlands.
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