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Brad Rolph, Senior Economist—Transfer Pricing Seminar—July 18



Kat Jennings

Brad Rolph is a Partner at Grant Thornton LLP in Toronto. He is one of Canada’s leading transfer pricing experts and was the first economist hired by any of the Big Four accounting firms in Canada to practice exclusively in the area of transfer pricing.

Mr. Rolph has been advising multinational companies on a variety of transfer pricing issues for more than 16 years. His practice is focused on audit dispute resolution: giving expert witness testimony, providing litigation support, negotiating advance pricing arrangements, and submitting representations to the Canada Revenue Agency’s Transfer Pricing Review Committee, competent authority, appeals, and field auditors. Mr. Rolph uses his experience resolving audit disputes to help his clients plan, implement, and document their transfer pricing policies before audit disputes arise. Prior to joining Charles River Associates to lead its Canadian Transfer Pricing Practice, Mr. Rolph was a partner and the chief economist of the National Transfer Pricing Group at Deloitte & Touche in Canada. Mr. Rolph is a frequent speaker at transfer pricing conferences and has written articles for transfer pricing publications. Prior to pioneering aspects of transfer pricing methodologies and documentation in Canada, Mr. Rolph was a tax and fiscal policy advisor at the Ontario Ministry of Finance. Mr. Rolph received his MA in Economics from Queen’s University and his BA in Economics from Wilfrid Laurier University.

Brad Rolph will be part of a panel discussing Global Transfer Pricing Developments including Brexit and his home country, Canada. Register Today and check out the whole schedule below:

Monday, July 18, 2016

8:00 AM – Registration and Continental Breakfast

8:45 AM – Introduction & Overview of Transfer Pricing

  • Introduction to transfer pricing
  • Sources of transfer pricing regulations, i.e., recent U.S. and global transfer pricing environments
  • Overview of U.S. transfer pricing methods
  • Examples of transfer pricing analyses
  • Penalties and documentation
  • Base Erosion Profit Shifting (BEPS) Overview

Brian Andreoli, CPA, International Tax Attorney & Consultant, New York

9:45 AM – Refreshment Break

10:00 AM – Transfer Pricing Documentation

  • Complying with inconsistent documentation requirement
  • Meeting the “contemporaneous documentation” requirements
  • Master file and local file: the OECD adopts the EU approach
  • Applying the reporting template by jurisdiction and by constituent entity
  • Implementation and Intercompany Agreements
  • Consistency with Other Reporting Requirements
  • Mandatory Disclosure Rules

Paul Chmiel, Executive Director, Ernst & Young LLP, New York, NY

11:15 PM – Transfer Pricing Examination and Audit Strategies

  • Preparing your “best method” audit defense
  • Defending your choice of transfer pricing method to the authorities
  • Factors that will trigger a tax audit
  • Types of information requests and taxpayer response strategies
  • Responding to draft proposed adjustments
  • Litigation preparation

Justin Donatello, Senior Manager, Repute Resolution & Controversy, KPMG LLP, New York

12:30 PM – Luncheon
1:15 PM – Advanced Pricing Agreements & Competent Authority

  • When to Consider an Advanced Pricing Agreements
  • The APA Process
  • Competent Authority Process
  • Arbitration

Steve Wrappe, National Leader, Transfer Pricing & Dispute Resolution, KPMG LLP, Washington, DC

2:45 PM – Refreshment Break
3:00 PM – Global Transfer Pricing Developments

  • Canadian Developments
  • Developments in Latin America (Brazil, Mexico, Argentina, Chile & Columbia)
  • Developments in Asia
  • The effect of BREXIT and other developments in Europe

Panel:
Brad Rolph, Partner, Grant Thornton LLP, Toronto
Mike Valdes, Partner, VD&T International LLC, Miami
Theodor van Stephoudt, Economist, Reed Smith, New York
Paul Tadros, President, DSN Consultants Inc., Atlanta

5:00 PM – Summit adjourns for the day

Tuesday, July 19, 2016

8:00 AM – Continental Breakfast

9:00 AM – Treatment of Intangible Transfer Pricing Provisions

  • Defining the definition, character, and attributes of intangibles
  • The characterization of “hard-to-value” intangibles
  • The role of the OECD provisions in ascertaining intangibles
  • The renewed importance of the legal ownership/contractual arrangement definition
  • Remuneration for developers and exploiters of the intangible

Paul Flignor, Principal Economist, DLA Piper LLP, Chicago

10:30 AM – Refreshment Break
10:45 AM – OECD final reports under its BEPS project

  • Limiting Base Erosion Involving Interest Deductions and Other Financial Payments
  • Countering Harmful Tax Practices More Effectively, Taking into Account Transparency and Substance
  • Disconnect between location of value created and profits
  • Preventing the Granting of Treaty Benefits in Inappropriate Circumstances
  • Developing a Multilateral Instrument to Modify Bilateral Tax Treaties

Uziel Alvarez, Principal, KPMG LLP, New York

12:45 PM – Question & Answers
1:00 PM – Conference Concludes

Conference Location

AMA Conference Center
1601 Broadway, 8th Floor, New York, NY 10019
212-903-8060

Hotel accommodations are at your discretion, we suggest:
Belvedere Hotel
319 West 48th Street, New York, NY 10036
Reservations (212) 245-7000
Type AMA in the Promo Box for 15% discount

The Crowne Plaza Times Square
1605 Broadway, New York, NY
Reservations: 212-977-4000

Register Now

Registration includes publication in electronic format, continental breakfasts, lunches and refreshments.

This basic to intermediate level seminar is for corporate tax, accounting and finance executives, transfer pricing specialists, economists, corporate counsel, CPAs, controllers, treasurers, tax attorneys. There is no advance preparation or prerequisites for this group-live seminar. (Field of Study: Taxes)

Kat Jennings founded www.taxconnections.com, the first tax media site promoting and marketing tax professionals worldwide. With a world of tax innovation at our fingertips, TaxConnections brings the the first Virtual Tax Offices in history to market.
While many companies talk about the future of Virtual Offices, Kat Jennings was the first to bring virtual offices to the cloud for professionals enabling them to work from any location in the world with a laptop and/or cell phone. With future iterations, our technology will be available to multiple business verticals and professionals worldwide.

Join today at: https://www.taxconnections.com/membership/tax-professionals or call 858.999.0053.

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