Dbriefs
29 Jun.

State transfer pricing audits: The case for planning ahead

Transfer Pricing

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

Participants will identify potential pitfalls in navigating state transfer pricing audits and explore practical ways to prepare for audit defense and planning.

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Key takeaways

Host: Mark Nehoray, partner, Deloitte Tax LLP

Presenters: Joe Garrett, Sarah Murray, and John Wells

1 Overview CPE credit | Taxes

Many states’ revenues have dwindled during the pandemic, so some tax authorities are increasing their enforcement of related-party transaction laws. How can tax executives prepare for novel approaches to state transfer pricing audits? We’ll discuss:

  • Recent enforcement actions taken by various states, including introduction of Advanced Pricing Agreement programs.
  • The Multistate Tax Commission’s recent actions to help states prepare for transfer pricing enforcement.
  • How to establish proper support, and what to expect during a transfer pricing state audit.

Meet the speakers

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.

Joe Garrett

Joe Garrett

Multistate Tax Group | Washington National Tax

Joe joined Deloitte Tax LLP in 2019 as a managing director in the Multistate Tax practice. Prior to joining Deloitte, Joe served as deputy commissioner for the Alabama Department of Revenue for 17 years. He began his state tax career in public accounting as a state and local tax manager in Atlanta. Joe is well known and respected in the state tax community for his strong tax technical skills, which he demonstrated regularly by working with other states’ tax officials on tax policy matters and subjects such as Wayfair and the state impacts of federal tax reform. Joe is the 2015 recipient of the Paull Mines Award, the Multistate Tax Commission’s award for significant contributions to state tax jurisprudence. He was also the State Tax Notes Notable Tax Administrator of 2016 and featured in that publication’s “Spotlight” article (September 2015). At the Alabama Department of Revenue, Joe led the state’s policy work addressing the state impact of federal tax reform and post-Wayfair implementation issues. Joe also served as a leader of the Multistate Tax Commission’s policymaking work on these and other significant state tax developments. His ability to connect with various states on tax technical or procedural issues provides a substantial benefit to clients. Joe holds a BS in finance from Auburn University, a JD from the University of Alabama School of Law and an LLM in taxation from University of Florida Levin College of Law.

Sarah E. Murray, JD

Sarah E. Murray, JD

National Multistate Tax | Deloitte Tax LLP

Sarah is a principal in Deloitte’s Multistate Tax practice. She leads the National Multistate Tax Services sub-service line and also leads the Multistate Restructuring practice. She focuses on state income, franchise, and transaction tax issues associated with corporate restructurings, mergers and acquisitions, and post-merger integrations. Sarah also has specific and deep experience with income, franchise, and transaction tax planning and implementation of strategies. More recently, Sarah has spent significant time analyzing the state impact of federal tax reform and has been a frequent speaker on the topic. Sarah has extensive knowledge of audits, refund analyses and transaction tax issues associated with companies in various industries. Industries of focus include Life Sciences, Retail, Consumer Products, Hospitality, and Energy.

Dr. John M. Wells

Dr. John M. Wells

Principal | US Transfer Pricing Leader

John leads Deloitte’s US Transfer Pricing (TP) practice and globally leads Deloitte’s Oil & Gas Industry for TP. With clients across the industry, John leads projects involving quantitative analysis, intangible valuation, finance, fiscal policy, and modeling. Recognized as Leading TP Adviser by Euromoney/Legal Media Group and “TP Best of the Best”.

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