About the Course
Introduction
This CLE/CPE course will guide attorneys and tax professionals on managing transfer pricing issues for small to mid-size companies (SMEs). The panel will discuss key tax provisions under current tax law that impact transfer pricing and strategies for intercompany agreements and avoiding penalties and audits. The panel will also present case studies and recommendations for multinational entities and their advisers to preserve cash and limit tax exposure.
Description
Transfer pricing is widely considered the most contentious tax issue for cross-border companies. However, many companies can realize significant tax and cash savings with a strategic approach to transfer pricing. In addition, transfer pricing also affects customs duties payable.
Cross-border companies typically operate through multiple corporate entities requiring intercompany transfer pricing arrangements, which the IRS, states, and foreign governments scrutinize. The IRS has the authority to review the transfer pricing methods of business entities generating foreign income and make adjustments under IRC §482, which typically results in a significant tax liability assessment.
Also, many states challenge intercompany transactions through statutes and regulations similar to IRC §482 to collect additional revenue. States that have not adopted IRC §482 or similar rules may also negate the effect of intercompany transactions through discretionary powers to adjust income, statutes requiring the addback of some intercompany payments, or the assertion of nexus principles for entities not physically present in the state.
Listen as our panel provides guidance on the laws and regulations affecting transfer pricing, methods to establish compliant intercompany arrangements, and techniques to manage transfer pricing challenges and penalties.
Presented By
Mr. Klug is a trusted attorney with extensive experience in taxation, corporate planning, mergers and acquisitions, and estate planning. With decades of experience advising clients on everything from corporate tax structuring and cross-border transactions to private equity, estate planning, and family office strategy, he brings a rare blend of big law pedigree and boutique, hands-on partnership.
Ms. Lee is a trusted tax advisor with extensive experience in navigating the complexities of U.S. tax law and tax treaties, offering strategic counsel to her clients in the areas of individual and business tax planning, compliance, and controversies, as well as domestic and international estate planning. She has been instrumental in facilitating new business entity formation and fund formation, ensuring that her clients remain compliant with corporate regulatory requirements. Ms. Lee is admitted to the California Bar and fluent in Korean.
-
This 90-minute webinar is eligible in most states for 1.5 CLE credits.
-
Date + Time
- event
Tuesday, September 22, 2026
- schedule
1:00 PM ET/10:00 AM PT
I. Transfer pricing: introduction
II. Rules governing transfer pricing arrangements
III. Transfer pricing life cycle for a multinational
IV. Importance of intercompany agreements
V. Tax authority challenges to transfer pricing
The panel will review these and other crucial issues:
- What is transfer pricing and what do SMEs need to know?
- Transfer pricing study: What is it, what does it entail, and what are the benefits?
- Transactions subject to transfer pricing rules
- Defining "related parties" for transfer pricing purposes
- Procedures governing the preparation and filing of transfer pricing documentation
- Standards and procedures that govern a tax authority's review of companies' compliance with transfer pricing rules
- Assessment of penalties for noncompliance with transfer pricing rules
Related Courses
Tax Considerations for Partnership and LLC Agreements: Key Provisions and Pitfalls to Avoid
Monday, November 30, 2026
1:00 PM ET/10:00 AM PT
Tax Implications of Stock-Based Compensation and Cost-Sharing Arrangements
Available On-Demand
