The Spring Technical Session of the IFA Eastern Great Lakes Region will examine recent transfer pricing issues and experiences coming out of China, India, Korea, Japan, and Brazil. Tax planning strategies along with tax accounting implications will be covered. There will also be an update to the recently enacted unified PRC Corporate income Tax Law. Details are as follows:
Date: Thursday, May 15, 2007
8:00 a.m. – 12:00 p.m.
Place: Masco Corporation
21001 Van Born Road
Taylor, MI 48180
Luncheon: 12:00 p.m. at Masco (optional)
Cost:
$25.00 (Member)
$40.00 (Non-member)
Please make checks payable to "International Fiscal Association"
Registration Form and Directions to Masco are available in the Document Folder - click on the link above.
PROGRAM AGENDA
For many multinational companies, Transfer Pricing has recently become the number one international tax challenge. Fiscal authorities that previously accepted the intercompany pricing arrangements established by taxpayers have become increasingly sophisticated and aggressive in asserting difficult standards and unfavorable assessments.
A panel of PricewaterhouseCoopers transfer pricing specialists will discuss a variety of timely transfer pricing issues and experiences encountered in some of the more challenging jurisdictions: China, India, Korea, Japan & Brazil. Topics to be covered include: (i) unique methodological approaches asserted (including treatment of items such as locational savings); (ii) assertion of permanent establishment and profits deemed attributable; (iii) current approaches to intangible property ownership and cost sharing arrangements; (iv) potential reactions to taxpayers' application of the new U.S. services regulations; and (v) examination / dispute resolution issues and experiences. Time will be reserved for panel questions and open forum discussion.
Included in the PricewaterhouseCoopers panel, among others, will be the following speakers:
Dr. Shunichi Tsutsui
Shunichi is a Managing Director in the Transfer Pricing group of PricewaterhouseCoopers LLP. Dr. Tsutsui's work includes international transfer pricing, antitrust, regulatory, and other practices in law and economics. He has also successfully managed more than 15 unilateral and bilateral APAs (Advance Pricing Agreements) with the NTA (National Tax Agency of Japan) and IRS (Internal Revenue Service). Taking advantage of his Japanese bilingual and cultural skills, Dr. Tsutsui has established a close working relationship with a number of the NTA APA office personnel and PwC Tokyo transfer pricing professionals. He is a regular visitor to the NTA and PwC Tokyo.
Bill Hahn
Bill is a Managing Director of Transfer Pricing, resident in the Detroit office. An accomplished author and speaker, he has over 18 years of transfer pricing and valuation experience focused on the automotive industry and manufacturing. In addition to automotive transfer pricing planning, APA and examination resolution projects for automotive clients, Bill also established and managed a transfer pricing practice in Mexico City, Mexico where he resided for three years. Bill holds a B.A. in Economics from Northern Illinois University and an M.B.A. from the University of Illinois. Bill is a published author and speaker on transfer pricing and recognized as one of the “World’s Leading Transfer Pricing Advisers” by Euromoney.
Michael Ho
Michael is a partner who leads PwC's China Desk in New York. He has practiced China tax in the firm's Shanghai office for 10 years. During his years, Michael has provided assistance to many companies on their investments into China, including such varied projects as: inbound structuring for a major US cinema group; feasibility assistance on establishment of an amusement park; procurement set-up for a French supermarket chain; acquisition of a state-owned asset for a Hong Kong property developer; tax audit defense for a US high-tech manufacturer; debt restructuring for a German engineering group; and cash repatriation for a Japanese insurance company. Michael has also supported clients in negotiations with Chinese partners and Chinese approving authorities as well as local Chinese governments (such as Shanghai and Hangzhou) on their investment policies. Michael is a member of the Chinese Institution of Certified Public Accountants.
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