Course Details

US Transfer Pricing

Structuring transactions among related parties operating in an international context provides opportunities for tax planning through the shifting of income to low-tax jurisdictions. Section 482 of the Code is the primary mean through which the federal government limits tax avoidance by requiring that the pricing of such transactions for tax purposes reflect the prices that would result if the parties were operating at arm's length. This course will examine the principal aspects of transfer pricing, focusing on the relevant statutory, regulatory, treaty, and case law, and will consider the historical and conceptual basis of the current system. Economic and tax accounting aspects of transfer pricing will be discussed along with the practical application of different transfer pricing methodologies. The course will also consider the administrative aspects of transfer pricing, including IRS examinations, APA procedures, and competent authority procedures. Guest speakers will provide students with their insights into real-world examples of transfer pricing studies, documentation, and controversies. PRE-REQUISITES/RESTRICTIONS: TAXLAW 670 International Taxation and BUSCOM 690 Basic Federal Income Taxation are pre-requisites for 3L JD students. Not open to 2L JD students who are not enrolled in the Joint JD-Tax Program without the permission of the instructor.

Catalog Number: TAXLAW 678
Practice Areas: Taxation Practice Area


Course History

Fall 2018
Title: US Transfer Pricing
Faculty: O'Brien-Penney, Andrew Ciaran
Welbel, Jonathan
Section: 1     Credits: 2.0
Capacity: 65     Actual: 22

Spring 2018
Title: United States Transfer Pricing
Faculty: O'Brien-Penney, Andrew Ciaran
Welbel, Jonathan
Section: 1     Credits: 2.0
Capacity: 59     Actual: 13

Spring 2017
Title: United States Transfer Pricing
Faculty: Cameron, David L. (courses | profile)
Section: 1     Credits: 2.0
Capacity: 59     Actual: 8

Spring 2016
Title: United States Transfer Pricing
Faculty: Cameron, David L. (courses | profile)
Section: 1     Credits: 2.0
Capacity: 59     Actual: 25