Dbriefs
3 Dec.

Post-transaction adjustments: Insights for year-end planning

Transfer Pricing

Thursday, 01:00 p.m.  ET | 1 hr 30 min
Credits offered: CPE Event language: English

Participants will discover how there could be ample time for their year-end transfer pricing planning and learn about various implications of and considerations for post-transaction adjustments.

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Key takeaways

Host: Mark Nehoray, partner, Deloitte Tax LLP

1.5 Overview CPE credit | Taxes

Transfer pricing has been a challenging proposition in this year of uncertainty. What options do US multinationals still have for year-end and post-transaction adjustments? We’ll discuss:

  • Planning considerations, including upcoming deadlines and ways to calculate an appropriate range of prices, markups, and other adjustments.
  • Indirect tax considerations, including possible issues with VAT, customs duties, and international tax considerations such as for BEAT, GILTI, and FDII.
  • Where and when end-of-year transfer pricing adjustments may be made and their reporting on CbC reports.
  • Financial accounting considerations under ASC 740.

Meet the speaker

Mark Nehoray

Mark Nehoray

Senior Partner Transfer Pricing | Deloitte Tax LLP

Mark is a senior partner in the Los Angeles office of Deloitte Tax LLP. He is a founding member of Deloitte’s national transfer pricing practice in March 1990, as well as the founding member of its Los Angeles transfer pricing practice. Mark has more than 36 years of public accounting and private industry experience, primarily in the international tax and transfer pricing areas. He consults with multinational clients on transborder transactions, assists multinational companies with transfer pricing studies, and consults with clients on restructuring of foreign royalties and other foreign income streams. Mark led the team that successfully negotiated Mexico’s first-ever transfer pricing ruling.

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Thursday, 3 Dec 2020 01:00 p.m. ET
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