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TP Minds Americas
2023 - Date TBC
USAFlorida

Alston & Bird

Profile

e know and use various approaches to help multinational groups avoid double taxation and benefit from operations in low-tax jurisdictions. Our goal is to minimize both the aggregate taxation of the multinational group consistent with its ongoing business operations and the compliance costs associated with achieving that result.

Our capabilities distinguish Alston & Bird from other firms that advise on transfer pricing matters. We have been among the leaders in creating innovative substantive and procedural solutions to resolve transfer pricing controversies. We helped develop the advance pricing agreement program by filing a request for an advance pricing agreement eight months before the IRS released the Revenue Procedure that created the program. We have introduced a number of transfer pricing methodologies that were at the time quite novel but have since become widely accepted, and we continue to help our clients by crafting unique and novel methodologies that fit their particular circumstances and business objectives while also satisfying the appropriate tax authorities.

As lawyers, we are skilled in analyzing factual material, organizing that material to communicate the benefits of particular transfer pricing methodologies both to government representatives and courts, and negotiating settlements, agreements, and similar documents that are needed to resolve transfer pricing disputes. Effective presentation of a taxpayer’s justification for selecting a transfer pricing method requires advocacy, drafting, and the other skills associated with the legal profession, as does negotiating with tax authorities to sustain the taxpayer’s transfer pricing on an ongoing basis.

The legal privilege accorded attorney-client communication and a lawyer’s work product allows for candid and complete discussions of approaches to develop and defend transfer pricing systems and methodologies. The privilege afforded to communications between us and our clients extends to communications among the client, the lawyer, and professionals that the lawyer retains to assist the lawyer in the engagement. You can be confident that your communications with us will remain confidential.

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  • IP Transfer Planning Options Under a New Global Tax Environment

    2:50pm
  • Best Practices and Strategies for Successfully Resolving Transfer Pricing Audits and Minimizing Controversy

    11:00am