International Tax Attorney, Brian Andreoli—Transfer Pricing Summit—July 18, 2016

Kat Jennings

Brian E. Andreoli is an international tax attorney and consultant in New York and focuses his practice on transfer pricing, international tax matters, and state tax matters. Mr. Andreoli has been a tax professional for more than 30 years, with experience in public, accounting, corporate (both foreign and domestic) law, and litigation.

He has tried cases and administrative hearings in the states of New York, Connecticut, Ohio, California, Virginia, North Carolina, South Carolina, Pennsylvania and Washington. These cases have concerned corporate income tax, sales and use tax, franchise tax and property tax. He also practices in voluntary disclosures for both corporations and individuals, concerning both civil and criminal penalties. Mr. Andreoli is admitted before the bars in Connecticut, New York, Massachusetts, and the District of Columbia, and is a Certified Public Accountant. He is licensed to practice in the United States Tax Court, Second Circuit Court of Appeals, the United States Supreme Court, and the Federal District Courts of the District of Columbia, Connecticut, Massachusetts, and New York (Southern and Eastern). He has been listed in the 2008 Guide to the World’s Leading Transfer Pricing Advisers.

Brian Andreoli will be presenting on Transfer Pricing Documentation. Check out the full schedule below and be sure to register today:

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

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

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)


As TaxConnections CEO, Kat Jennings founded the leading tax services marketplace for tax consultants and corporate decision-makers online. Our mission is building strong, trusted relationships between corporate tax and financial executives and tax experts providing a wide range tax services and resources worldwide. In addition to TaxConnections online “Find A Tax Professional” and “Ask Tax Question” search features, we also provide internationally recognized retained search services to multinationals who want “best in the profession” corporate tax executives. Contact or call 858.999.0053 at

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