TEI - Detroit Chapter

All Day Seminar - International

  • 04 Dec 2008
  • 8:00 AM - 5:00 PM
  • MSU Management Education Center, Troy



TEI Detroit

December 4, 2008

Baker & McKenzie

MSU Management Education Center

Troy, Michigan


            8:30 a.m. – 10:00 a.m.    Contract Manufacturing In Light of the Proposed Regulations


Speaker:          Robert J. Cunningham


Description:  This presentation will commence with a brief introduction to the foreign base company sales income provisions of Section 954, including the manufacturing exception and branch rules.  The presentation will then discuss the recent proposed contract manufacturing regulations, uncertainties with respect to such regulations, and planning opportunities and pitfalls of which taxpayers should be aware.


10:00 a.m. – 10:15 a.m.                     Break


10:15 a.m. – 11:25 a.m.                     Recent Developments in International Tax Planning


Speaker:          Trevor G. Bowler


Description:  This presentation will focus on the recently issued proposed regulations on outbound transfers of assets under Sections 367, 1248 and 6038B, as well as the underlying transactions giving rise to the release of same.  Other international tax recent developments, including repatriation planning, will also be discussed.  [NOTE:  Depending on what happens with the proposed section 987 regulations, Section 987 may be addressed as well.]


11:25 a.m. – Noon       An Overview of 2008 Transfer Pricing Developments


Speaker:          Robert J. Cunningham/Richard L. Slowinski


Description:  This presentation will discuss transfer pricing developments over the past year, including regulatory and judicial developments, with a particular emphasis on those developments that are likely to impact planning international transactions.


Noon – 1:00 p.m.                                Lunch


1:00 p.m. – 2:15 p.m.                         Tax Treaty Developments---Developments Related to International Tax Planning, including Transactions with Canada


Speaker:          Brian D. Segal


Description:  This presentation will be a discussion of recent tax treaty developments as they pertain to international tax planning.  Of particular emphasis will be the recent US/Canada Treaty Protocol and the use of arbitration under the treaty. 



2:15 p.m. – 3:15 p.m.    Using Advance Pricing Agreements and the Competent Authority Process to Resolve Transfer Pricing Matters, with Commentary on  Select Emerging Markets


Speaker:          Robert J. Cunningham/Richard L. Slowinski


Description:  This presentation will discuss how companies can use APAs and the CA process to resolve cross-border transfer pricing issues.  It will also discuss experience in addressing transfer pricing issues involving  selected emerging markets (e.g., Mexico, Russia, India, China and Korea) and provide practical advice on handling transfer pricing matters between the US and these emerging markets.


3:15 p.m. – 3:30 p.m.                         Break


3:30 p.m. – 4:30 p.m.                         Transfer Pricing Considerations for International Joint Ventures     


Speaker:          Richard L. Slowinski


Description:  This presentation will discuss the application of the transfer pricing rules to US and foreign joint ventures involving US-based and foreign joint venture partners, including issues relating to control, tangible goods, intellectual property and services.  We will use case studies based on real-world situations to illustrate certain important points.   


4:30 p.m. – 5:00 p.m.       Potential International Tax Reform Proposals      


Speaker:   Group               


Description:  This presentation will outline some of the potential international tax reform proposals taking into account the possible implications of the Presidential and Congressional elections.   




© TEI - Detroit Chapter
Powered by Wild Apricot. Try our all-in-one platform for easy membership management