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Transfer Pricing for Multinationals: Practical Insights for Attorneys

SKU: TAX6500
Total Credits
1 - 2
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Transfer pricing is widely considered the most contentious and expensive tax issue facing multinational companies today. However, many companies struggle to navigate the competing requirements of the IRS and international tax authorities.

This CLE course will provide insights into how attorneys can identify and assess client global transfer pricing issues from a practical perspective. The course explains the requirements of Section 482, Section 6662 documentation standards, and the OECD Transfer Pricing Guidelines. Lessons learned from Coca-Cola’s recent $9 billion tax court loss will also be reviewed.

Lecturer Bios

Steven G. Cappellino, Esq.

Steve is a member of Varnum’s Tax Practice Team. He has substantial experience in federal, state and local taxation, in both planning and controversy. Steve previously held positions at both a large international accounting firm and the IRS Office of Chief Counsel. During his 12-year career with the IRS, Steve served as a Special Trial Attorney, handling large business tax cases of national significance. Prior to that, he was a Senior Attorney, advising IRS auditors, managers and executives on domestic and international issues, as well as tax procedure. As a CPA in the accounting firm, Steve provided compliance (federal, state and local), consulting and controversy services. He also has a background in sales, use and personal property taxes.

Steve has extensive experience in the entire tax process, from audit inception through the appeals process and litigation. His technical experience spans corporate (both C and S corporations), partnership and individual taxpayer issues at the federal, state and local level. He also has experience in international taxation, including transfer pricing and inversions, as well as the judicial doctrines.

Steve is also a member of Varnum’s Business and Corporate Services Team, advising both startups and mature businesses on issues including acquisitions, sales, mergers, succession planning, private equity and financing.

Alexander Martin

Alex Martin is Principal and Transfer Pricing Practice leader at KBKG, a nationwide tax specialty firm. KBKG was named one of the world’s leading transfer pricing consultancies by International Tax Review for 2021-2022.

Alex has 24 years of full-time transfer pricing experience working in Washington, D.C.; Melbourne, Australia; and Detroit, Michigan over the course of his career. As a transfer pricing economist, Alex worked for a Big-4 firm for 12 years as a director, a top middle-market focused firm for six years as a principal, and four years as president of an independent transfer pricing consultancy. Alex has assisted companies in many industries addressing transfer pricing issues on a US and global basis, including transfer pricing documentation, audit defense, and Advance Pricing Agreements (APAs).

Alex is best known for developing practical solutions for complicated transfer pricing issues, and he has published numerous articles based upon his time-tested transfer pricing strategies. He continues to be a sought-after transfer pricing speaker for CPA firms, attorneys, and other professional service firm networks. Alex has a Bachelor of Science in Economics from Tulane University and a Master’s Degree in Public Policy from the University of Michigan.

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