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Understanding the Complexities of Form 5472 and Its Transfer Pricing Implications

 

Learn what you need to know about Form 5472 including reporting guidelines and how to complete it properly.

Many companies who are required to prepare annual transfer pricing documentation and support for their intercompany transactions often do not understand that they need to do so, or what is needed in order to satisfy the US transfer pricing regulations. Additionally, these same companies likely do not understand the serious impacts transfer pricing has on their annual corporate income tax return, leaving them exposed to potentially large proposed tax adjustments and double taxation in the event of an IRS examination. This presentation will help attendees understand first what the transfer pricing rules and requirements are, and then how to intelligently comply while also keeping in mind any possible tax planning opportunities transfer pricing tends to present.

Agenda

Faculty

Carl Budenski

Carl Budenski

Aprio

  • Director and Co-leader of Aprio’s National Transfer Pricing Practice, also leading Aprio’s burgeoning Benelux practice
  • Aprio’s transfer pricing expertise spans various global industries such as manufacturing, distribution, technology, and digital assets, with dedicated country groups for UK, Germany, Korea, China, Japan, and Australia/New Zealand
  • Conducted numerous seminars and trainings on transfer pricing, and how it impacts businesses around the world, including a recent engagement for the Belgian Chamber of Commerce
  • Author of numerous articles regarding transfer pricing
  • M.S. degree in Finance and Economics, West Texas A&M University; B.B.A. degree in both Finance and Economics, magna cum laude, Drake University
  • Can be contacted at (470) 694 6218; [email protected]; or https://www.linkedin.com/in/carl-budenski/
Yan Jiang

Yan Jiang

Aprio

  • International Tax Consulting and Tax Director at Aprio
  • Experience includes addressing the tax complexities associated with a variety of multinational business structures and cross-border transactions
  • Extensive experience in international mergers and acquisitions, such as tax due diligence and restructuring
  • Has assisted clients with various transactional projects dealing with international tax risk assessment, U.S. anti-deferral tax planning (CFC, Subpart F income, GILTI, foreign tax credit), and offshore cash expatriation
  • Conducts both public and private seminars in the international tax area, recently delivering a series of international tax training sessions to a global financial institution, educating its bankers with the knowledge to navigate their clients’ cross-border tax issues
  • M.B.A. degree and M.S. degree in Accounting, California State University, Los Angeles
  • Can be contactad at (240) 630-1032; [email protected]; or https://www.linkedin.com/in/yan-jiang-6a570831/

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