EY International Tax Webcast

BorderCrossings with EY's transfer pricing and tax professionals

A conversation with Sam Maruca, Director, IRS Office of Transfer Pricing Operations (TPO)

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Sam Maruca, soon to celebrate his third anniversary as Director of the TPO, will share the latest on Internal Revenue Service (IRS) transfer pricing operations.

Mr. Maruca will talk openly about the IRS’ goals, strategies, and tactics in improving taxpayer upfront compliance and making IRS transfer pricing enforcement more effective.

This webcast will provide the audience with a unique opportunity to engage with Mr. Maruca on a wide range of important transfer pricing issues. Among the topics to be covered:

  • IRS strategies for assessing transfer pricing risk and selecting cases for examination
  • IRS efforts to “take back the audit” by using new procedures and tools such as the recently issued “audit roadmap” and revised information document request (IDR) directives
  • The status of the international practice networks (IPNs) dealing with transfer pricing
  • The evolving rules of engagement between IRS exam teams and the new Transfer Pricing Practice (TPP)
  • The latest news from the Advance Pricing and Mutual Agreement (APMA) Program
  • The recently issued IRS notices updating the APA revenue procedure and the Competent Authority revenue procedure
  • The TPO’s involvement with and views about the OECD’s Base Erosion and Profit Shifting (BEPS) project and ongoing revisions to Chapter 6 of the OECD Guidelines dealing with intangibles

During this live, interactive webcast, you will have the opportunity to ask questions through the website and Mr. Maruca and the EY panelists will answer as many of your questions as time permits.

This program will be of interest to vice presidents/directors of tax/international tax/transfer pricing/customs/global trade, directors of finance, CFOs, international tax managers and tax accountants looking for the latest practical information and guidance to support their global business initiatives. We hope you will be able to join us.

 

Save the date for the next BorderCrossings webcast:

1:00–2:15 p.m. EDT New York/Toronto; 10:00–11:15 a.m. PDT Los Angeles/Vancouver

  • Wednesday, 28 May 2014

 

Panelists:

Sam Maruca

Director, IRS Office of Transfer Pricing Operations

Sam Maruca was appointed in May 2011 as the first IRS director of transfer pricing operations. In that position, he is responsible for the development and coordination of LB&I's overall transfer pricing strategy and resourcing. The Advance Pricing and Mutual Agreement program (APMA) and the new, field-focused Transfer Pricing Practice (TPP) are under his direction.

Sam has been a tax lawyer in private practice in Washington since 1982. For the past 20 years, he has specialized in large-case dispute resolution, focusing primarily in the international tax and transfer pricing areas. During his career he has successfully resolved many complex and contentious cases, at the audit level, in Appeals, in competent authority, in the APA program, and in the courts. These matters have arisen in a broad range of industries, including pharmaceuticals, information technology, communications, media and entertainment, homebuilding, specialty materials, and retail. He has written and spoken extensively on transfer pricing topics.

Sam received a B.A. degree from Yale College in 1977 and a J.D. degree from Georgetown in 1982.

Ken Christman

Transfer Pricing, Ernst & Young LLP

Kenneth P. Christman Jr. is a member of Ernst & Young LLP's International Tax Services practice. He is also a member of the National Tax Department and is based in Washington, DC, where he works in the Transfer Pricing practice.

Ken advises large multinational clients on transfer pricing controversy, planning and structuring, with a particular emphasis on cross-border transfers of intellectual property, the provision of financial services and cost sharing arrangements. He also represents clients under audit by tax authorities and before the Internal Revenue Service (IRS) Appeals function. Prior to joining Ernst & Young LLP in February 2010, Ken was an attorney with the IRS in Branch 6 (the transfer pricing branch) of the International Division.

Ken received his Bachelor of Arts, magna cum laude, Phi Beta Kappa, from Princeton University; his Juris Doctor from Yale Law School; and a Master of Laws in Taxation from New York University School of Law.

Moderator:

Craig Sharon

Transfer Pricing, Ernst & Young LLP

Craig Sharon is a member of Ernst & Young LLP’s Transfer Pricing practice. He is based in Washington, DC, but spends considerable time on the west coast.

Craig practices in all aspects of transfer pricing planning, compliance, and controversy and has particularly deep experience with advance pricing agreements (APAs) and competent authority proceedings. Prior to joining Ernst & Young LLP in May 2013, Craig served as the IRS APA director from 2008-11. As APA director, Craig was a member of the senior executive team within the IRS Office of Associate Chief Counsel (International) (ACCI), and in his last year with the IRS, Craig was intimately involved in the development of the restructuring plan that led to the creation of the IRS Large Business & International (LB&I) Division and the merged Advance Pricing Agreement and Mutual Assistance (APMA) Program.

Craig received his BA in Economics from the University of Idaho and his JD from Georgetown University Law Center. He was an adjunct transfer pricing professor in the graduate tax program at Georgetown law from 2006 to 2012. Craig is also a frequent writer and speaker on transfer pricing and related international tax issues.