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Implications of Recent Transfer Pricing Decisions: Medtronic and Eaton

CPE 1.0


Webcast overview

KPMG LLP (KPMG) is pleased to invite you to a one-hour TaxWatch webcast that will cover two significant recent court decisions and what they could mean for transfer pricing more broadly.

Mark Horowitz and Lillie Sullivan from the KPMG Washington National Tax – Tax Controversy and Dispute Resolution team will join Jack O’Meara and Thomas Bettge from KPMG Washington National Tax – EVS, specializing in transfer pricing to:

  • Provide an overview of the recent Medtronic and Eaton decisions.
  • Discuss the Medtronic decision’s immediate and long term impact on comparability and method selection, including implications for the selection and application of comparable transaction-based methods versus the Comparable Profits Method (CPM) or other methods.
  • Discuss Eaton’s unqualified Sixth Circuit win in its long-standing battle with the IRS over the latter’s attempt to cancel two unilateral Advance Pricing Agreements (APAs), including what this decision means for taxpayers with APAs.

After registering, you will receive details on how to log into the Webcast or dial in for audio only. Continuing professional education (CPE) credit is available for U.S. participants who meet the eligibility requirements.

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