When a taxpayer receives an information document request (“I.D.R.”) from the I.R.S. for transfer pricing documentation, it should know what to expect: a lengthy, contentious process of documenting and defending its tax position. Pausing to think objectively about the cognitive biases, strengths, and weaknesses underlying a transfer pricing position is an essential step to take before delving into the technical aspects of the examination itself.

This program will describe the unique challenges for mid-sized companies in planning, implementing, documenting, and managing controlled cross-border transactions and in dealing with tax authority controversy. Best practices and key points for advisors will be presented to explain how a company can meet its compliance obligations while acknowledging actual business practices.