Are state transfer pricing audits on your radar? They should be. Join Stacey Roberts and Davinia Lyon as they dig into the issues around state transfer pricing audits, from big global picture down to the nitty-gritty state and local tax issues.
Wednesday, June 2, 2021
1:00pm-2:50pm EDT, 10:00am-11:50am PDT
A live 110-minute CPE webinar with interactive Q&A
This webinar will discuss the rise in state challenges of transfer pricing arrangements. Our panel of SALT veterans will cover choosing, documenting, and defending intercompany pricing agreements for multistate businesses.
Description
Pricing arrangements between related parties should reflect the fair market value of goods and services exchanged. With adequate methodologies, prices charged and paid would mirror the prices between unrelated parties so that related parties don’t avoid taxation or benefit unduly. There has been a recent surge in state examinations of perceived transfer pricing abuses.
Using IRC Section 482 as a base, some states scrutinize intercompany transactions to see if prices used are arms-length and the “best method” is being used. Other states rely on their own add-back statutes, forced combinations, and nexus determinations to challenge these arrangements. Since intercompany transactions are eliminated in a combined filing, many states use forced combinations as a resolution stating that separate filings lack economic substance. Taxpayers with proper transfer pricing studies have been able to defend separate filings successfully.
SALT practitioners working with multi-state companies need to understand transfer pricing methods and challenges to assist multistate clients in structuring and defending these arrangements.
Listen as our panel of SALT experts explains transfer pricing methods, the best method analysis rule, current cases, and defending pricing arrangements between related entities.
Outline
- State transfer pricing overview
- IRC Section 482
- Pricing studies
- State-specific methods
- Transfer pricing enforcement
- Defending transfer pricing arrangements
- Best practices
Benefits
The panel will review these and other critical issues:
- Selecting appropriate transfer pricing methods
- Documenting pricing arrangements
- How specific states are challenging transfer pricing arrangements
- Implementing the best method for pricing arrangements
- How states incorporate the rules under IRC Section 482
FACULTY
Stacey L. Roberts, CPA
State and Local Tax Director
TaxOps
Ms. Roberts has been making SALT less taxing for over a 1,000 businesses over the last 25 years. As a director of the SALTovation team at TaxOps, she is at the table-and in the weeds-helping guide dynamic businesses through compliance and strategic planning that minimizes risk and strengthens tax positions. Ms. Roberts entered the accounting field with Andersen Worldwide/Andersen LLP, where she began to hone her state and local tax experience. She added stints at KPMG and Deloitte before moving in-house with Ball Corporation as their manager of State and Local Tax Administration. An interlude with a regional tax firm followed before Ms. Roberts joined TaxOps. She is a frequent speaker and author on SALT issues for industry and professional organizations including the Denver Tax Institute, Product PowerUp, NowCFO and more.
Davinia Lyon
Partner
TaxOps
Ms. Lyon specializes in corporate and international tax and planning, including income tax provisions (ASC 740), business strategy tax impact analysis, transfer pricing, foreign compliance and reporting, M&A transaction and entity restructuring. She also counsels clients under audit and in their efforts to develop corporate tax departments and related support areas.
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