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International Taxation: Introduction to U.S. Transfer Pricing, Part II

SKU: TAX4700
Total Credits
1.5 - 2.5
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In this CLE course you will learn the statutory and regulatory history of how the U.S. has priced controlled transactions between controlled taxpayers that involve intangible property. As part of this history we will explore the new provisions of the Tax Cut & Jobs Act, that affect intangibles and transfer pricing. We will analyze the concepts around intangible property that inform both U.S. transfer pricing between taxpayers and the Internal Revenue Service, as well as transfer pricing between the Internal Revenue Service and the governments with whom the U.S. has entered tax treaties. These concepts include but are not limited to: the commensurate with income principle, aggregation, realistic alternatives, and cost sharing, and Pillar 1 and Pillar 2 of the OECDs proposals.

Lecturer Bio

William Lundeen, Esq.

Bill Lundeen has served in tax positions in all three branches of the federal government: on Capitol Hill, at the United States Tax Court, and at the Internal Revenue Service as a Senior Counsel Attorney and Tax Law Specialist. At the IRS Bill negotiated multi-lateral APAs concerning global trading of derivatives and he and his teams resolved double tax disputes with other governments. For four years Bill was appointed as the General Counsel of the State of Illinois Department of Revenue with ultimate responsibility for all Illinois tax law positions taken during that time.

In the private sector Bill began his legal career in New York City with the renowned boutique tax law firm of Everett, Johnson and Breckinridge, a member of the Miller & Chevalier network of tax law firms. Bill also provided multi-state and international tax controversy services to clients as a partner in two public accounting firms most recently Ernst & Young LLP. At EY he served as Partner and Midwest Practice Leader of the Tax Controversy and Risk Management Services team which represented clients before the Internal Revenue Service Large Business & International Operating Division and before the IRS Office of Appeals. In addition to ultimate responsibility for all Illinois tax litigation between 1995-1999, Bill had specific responsibility for the federal government’s win in Intergraph Corporation v Commissioner a case of first impression under section 988, and Bill has advised the IRS on issues docketed with the U. S. Tax Court.

Bill is a graduate of the University of Arizona where he was a member of the accounting honor organization, Beta Alpha Psi. He received his Juris Doctor from the University of Virginia where he served as an Articles Editor of the Virginia Tax Review and he received his LL.M. in Taxation from New York University.

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