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Liz Chien at Tax Law Conference

March 5

KEY TRANSFER PRICING PLANNING CONSIDERATIONS POSTTCJA AND BEPS 2.0
This panel will evaluate how the TCJA, OECD BEPS 2.0 and other
developments challenge the viability of the arm’s length standard
as a foundational transfer pricing planning concept.
• Addressing transfer pricing planning challenges in a world of
increasing automation, machine learning and digitalization.
• How taxpayers are approaching transfer pricing aspects of IP
migration and intercompany transactions post TCJA.
• Interaction of arm’s length range and TCJA provisions (e.g.,
BEAT, FDII).
• An update on OECD BEPS developments and considerations
for taxpayers’ intercompany transactions.
Angela Holland, Senior Counsel, I.R.S. Office of Chief Counsel
(INTL) (moderator)
Christopher Bello, Branch Chief, I.R.S. Office of Chief Counsel
(INTL)

Liz Chien, Vice President of Global Tax and Chief Tax Counsel,
Ripple Labs, Inc.

David Ernick, Principal, PwC
Brian Jenn, Partner, McDermott, Will & Emery LLP

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