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2021 76th Annual Conference


MON07 - Collateral Consequences of Global Transfer Pricing Disputes


Oct 25, 2021 11:00am ‐ Oct 25, 2021 12:00pm

Description

This session will discuss the fallout from resolving disputes regarding transfer pricing adjustments and highlight the major issues arising therefrom.

After this session, participants will be able to: 

  1. Identify the major actions companies need to take after a final transfer pricing adjustment
  2. Assess and take action upon any section 905(c) foreign tax credit redeterminations arising from such adjustments
  3. Determine whether any “constructive” transactions need to be accounted for U.S. tax purposes as a result of such adjustments

Moderator(s):

Speaker(s):

Tags: IRSAA INTL

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