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
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)
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