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Archive for January, 2021

Transfer Pricing Risk Management Zoom Team-Based Case Studies Start Tuesday, Jan 19, run until May

Posted by William Byrnes on January 8, 2021


Based on weekly case studies created by the faculty, supported by reading/text materials, pre-recorded videos with PPTs, and audio podcast files made by the faculty – twice-weekly Zoom live sessions (recorded as well) of 90 – 120 minutes wherein students in teams work through the case studies generally from an assigned stakeholder perspective. Access to the extensive Texas A&M library for case study research includes by example: Lexis, Westlaw, IBFD, Kluwer-Cheetah, Thomson OneSource, BvD (Moodys), S&P CapIQ, FITCH, among several others. Apply for Texas A&M’s courses here.

Professor William Byrnes’ leverages the expertise of weekly case study experts that draw from a variety of disciplines including accounting, economics, finance, international business, management, and law. The textbook is authored by Professor William Byrnes and provided within the course [William Byrnes, Practical Guide to Transfer Pricing, 4th ed, 2021 version, published by Matthew Bender via LexisNexis and available in the law library in hardcopy].

Transfer pricing is the valuation of cross-border transactions between units of a multinational enterprise. This course introduces students to both theoretical and practical aspects of transfer pricing. This course deep dives into the legal issues (regulations and jurisprudence); accounting systems and variances among (managerial, financial, tax, and public accounting); financial data analytics through the lens of economic methods and profit level indicators; functional analysis and global value chain; contrasts with the OECD Transfer Pricing Guidelines and UN Transfer Pricing Manual. Each week, an industry-based case study is undertaken in a team-based learning approach of student groups generally consisting of three team members each.  The industry case studies include, as examples, agriculture (coffee supply chain), technology services, and petroleum.

Part I and Part II of this course both address strategy, compliance, and risk management.  Transfer Pricing Part I focuses on the topics of comparability, the transfer pricing methods, functional analysis and global value chain analysis, and transfer pricing analysis for tangibles. Transfer Pricing Part II focuses on the transfer pricing methods and analysis for intangibles and for services. Topics more specifically that are addressed in this course via its textbook, video and audio lectures, weekly team-based case studies, and weekly live sessions, include the arm’s length standard, comparability analysis, risk analysis for tangibles and intangibles, transactional methods (CUP, CUT, Cost Plus, Resale Minus, Commodity), profit methods (e.g. comparable profits method, transactional net margin method, profit level indicators, key performance indicators, commensurate with income), functional analysis (supply chain, global value chain analysis, DAEMPE functions), industry economic data gathering and analysis, cost-sharing arrangements, profit splits and residuals, platform contributions, and safe harbors.  Documentation, advance pricing agreement procedures, and mutual agreement procedures are topics addressed in the courses of “International Tax Risk Management I” and of “FATCA, CRS, and CbCR”. Apply for Texas A&M’s courses here.

Course Topics and Calendar

Week 1 January 19 Arm’s Length Standard case study by Dr. Bruno da Silva

Jan 19 Tuesday at 9am – 10:30am (2-minute student introductions, orientation to teamwork and case studies, expectations and obligations regarding participation asynchronously or synchronously, discuss the syllabus, set up first-week case study)

Jan 24 Sunday at 10am – noon (presentations, peer feedback)

Week 2 Jan 26: CUP & Comparables, Eden Hofert – the Christmas Tree case (Canadian)/Compaq by Dr. Lorraine Eden

Jan 26 Tuesday at 9am – 10:30am (2-minute student introductions, orientation to teamwork and case studies, expectations and obligations regarding participation asynchronously or synchronously, discuss syllabus, set up first week case study)

Jan 29 Friday at 9am – 10:30 (presentations, peer feedback)

Week 3 Feb 2: Cost Plus & Resale Minus (Byrnes’ Starbucks case study) by Dr. George Salis

Feb 2 Tuesday at 9am – 10:30am

Feb 7 Sunday at 10am – 11:30 (presentations, peer feedback)

  • Watch background and overview videos of big data & econometrics as it is used in transfer pricing.
  • Read textbook Chapter 7 then read chapter 6.
  • Contrast the analysis within the Cost Plus Method and Resale Minus Method cases.
  • Each team has a stakeholder role in Byrnes’ case study of Starbucks cost inclusion and exclusion, agriculture supply chain, and coffee global value chain.

Week 4 Feb 9: Comparable Profits Method & TNMM by Dr. George Salis

Feb 9 Tuesday at 9am – 10:30am (discussion about Byrnes’ case study and the CPM)

Feb 14 Sunday at 10am – 11:30 (presentations, peer feedback)

  • Read textbook chapters 8 and 9.
  • Watch second set of videos of big data & econometrics.
  • Review the CPM/TNMM examples.
  • Teams prepare the Case Study.

Week 5 Feb 16: functional analysis & global value chain, profit split methods by Dr. George Salis

Feb 16 Tuesday at 9am – 10:30am (discussion about Byrnes’ case study and the CPM, GVC)

Feb 21 Sunday at 10am – 11:30 (presentations, peer feedback)

  • Read textbook chapters 11 and 12, skim chapters 97 and 98
  • Watch videos about FA and GVC.
  • Review the GVC examples (chapters from textbook regarding coffee, technology, tobacco).
  • Team’s prepare the Case Study.

Week 6 Feb 23 Best Method – Snowin’ and Blowin’ case study by Dr. Lorraine Eden

Feb 23 Tuesday at 9am – 10:30am

Feb 26 Friday at 9am – 10:30 (presentations, peer feedback)

  • Read textbook chapters 15 and 16
  • Watch video.
  • Team’s prepare the Case Study.

Week 7 March 2 Capstone summation and tax risk technology presentations

March 2 Tuesday at 9am – 10:30am (counsel litigation discussion)

March 5 Friday at 9am – 10:30 (tech provider training)

Week 8 March 15: Intangibles Royalty Rates CUT and CPM by Dr. Debora Talutto

March 16 Tuesday at 9am – 10:30am (counsel litigation discussion)

March 21 Sunday at 10am – 11:30 (tech provider training)

  • Read textbook chapter 10
  • Analyze the CUT cases
  • Case Study presentation

Week 9 March 22: Intangibles Buy In/Out Cost Sharing Arrangements, Platform Contribution Transactions by Dr. George Salis

March 23 Tuesday at 9am – 10:30am

March 28 Sunday at 10am – 11:30 (presentations, peer feedback)

  • Read textbook chapter 13
  • Analyze the CSA/PCT cases
  • Case Study presentations

Week 10 March 29: Digital; Unitary Apportionment; Pillar 1; EU State Aid

by Dr. Bruno da Silva dasilva.brunoaniceto@gmail.com

March 30 Tuesday at 9am – 10:30am

April 2 Friday at 9am – 10:00 (presentations, peer feedback)

  • Read textbook chapters 44 and 75
  • Review Pillar One
  • Case Study presentation

Week 11 April 5: Digital –Amazon, Internet of Things (IOT) by Dr. Lorraine Eden and Dr. Niraja Srinivasan

April 6 Tuesday at 9am – 10:30am

April 9 Friday at 9am – 10:00 (presentations, peer feedback)

  • Read OECD Pillar 1 comment letters in the course folder
  • Read Lorraine Eden’s articles
  • Read Chapter 46

Week 12: April 12 Services by Hafiz Choudhury

April 13 Tuesday at 9am – 10:30am

April 16 Friday at 9am – 10:00 (presentations, peer feedback)

Week 13 April 19: Restructuring (and extractive industry experience) by Hafiz Choudhury

April 20 Tuesday at 9am – 10:30am

April 23 Friday at 9am – 10:00 (presentations, peer feedback)

  • Read textbook chapters 27, 43
  • In the second week, the investors find out that the state owned off take customer is not utilizing the full capacity of the FSRU

Week 14 April 26 Capstone presentations for comment letters

April 27 Tuesday at 9am – 10:30am

April 30 Friday at 9am – 10:00 (presentations, peer feedback)

  • Review past comment letter submissions
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