New Bloomberg BNA Webinar Examines a World of Contention: The Valuation of Intangibles
ARLINGTON, Va., April 2, 2012 /PRNewswire-USNewswire/ --Since the early 1960s, the migration of intangibles from U.S. research and development activities to related offshore subsidiaries has been a major concern of U.S. tax policy. The destination of intangible migration has since shifted to lower tax jurisdictions abroad, but the resulting tax issues have not been resolved – as will be discussed in a new Bloomberg BNA webinar, The Valuation of Intangibles, on April 4, 2012.
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A major issue of contention between legislators, the IRS, and corporate tax professionals is the valuation of these intangibles, for which the IRS has promulgated several specified methods – none of which can find comparable "super royalty" rates for high profit potential intangibles. This webinar, The Valuation of Intangibles, focuses on the problems that the IRS and corporate professionals face when confronted with transfer pricing ("arm's length") principles based on comparables, and the challenge to find comparables to evaluate the migration of high profit potential intangibles.
In 60-90 minutes, the webinar will cover:
- Transferring Intangibles: A Regulatory Context
- The Arm's Length Standard
- Definition of Intangible Property
- Pricing Methods
- Comparable Uncontrolled Royalty Rates – Scenario and Example
- Comparable Uncontrolled Royalty Rates Under the CPM
- Lump-Sum Royalty Payment
- Equivalent Royalty Amount
- Calculation of the Equivalent Royalty Amount
- Sensitivity Analysis of the Income Method
- Periodic Adjustment
- Enhancement to the Intangible
Registrants attending this webinar will be able to:
- Understand the comparable royalty rates under the CUT method
- Know the manufacturing markup and distribution margin under the Residual Profit Split Method
- Forecast royalties, and incorporate upfront fees and milestone payments under the Present Value Method
- Communicate complex transfer pricing pitfalls to clients interested in intangible migration
About the Speaker
Ednaldo Silva is a transfer pricing economic consultant based in Washington, D.C. Prior to starting his company, RoyaltyStat, Ednaldo was chief tax economist at the international law firm Shearman & Sterling, and before that he was senior economic advisor to the IRS Office of Chief Counsel. Ednaldo participated in the drafting of the 1994 transfer pricing regulations, and introduced the comparable profits method when he was an audit economist in Manhattan. Ednaldo introduced several other innovations in transfer pricing practice, including the concept of "best method" based on statistical reliability principles, and the use of quartiles and Tukey's filter to deal with pervasive outliers among operating profit indicators of potential comparables. Ednaldo was the first economist in the APA program, which was used as a nursery school for application of the comparable profits method. He has extensive experience as a tax economics expert, having represented the IRS and corporate clients in several major cases of transfer pricing litigation.
The Valuation of Intangibles takes place April 4, 2012 from 12:30 p.m. – 2:00 p.m., (ET). To register for this webinar and obtain further information about CLE and CPE credits, go to http://www.bna.com/valuation-intangibles-w12884908512/?utm_source=newswire&utm_medium=PR&utm_content=TM&utm_campaign=Webinar-04042012 or (in the U.S.) call 800.372.1033, menu Option 6, then Option 1. The per site fee is just $249.
To receive automatic, email notification of upcoming BNA webinars that may be of interest to you, go to: http://www.bna.com/emailsignup.htm
About Bloomberg BNA Webinars
Bloomberg BNA is the foremost source of tax and accounting research, news, practice tools, and guidance for tax attorneys, CPAs, corporate tax managers, estate planners, and financial accountants. Designed for today's busy practitioners, our webinars offer the same expertise and relevance that are the hallmark of all Bloomberg BNA resources. In just 60-90 minutes, practitioners gain in-depth knowledge on a current tax or accounting topic from experts in that area — and benefit from practical applications that can be put to work immediately. Conference attendees have the opportunity to ask the speakers questions, and may be eligible to earn CLE or CPE credits — all from the convenience of their own office or conference room.
About Bloomberg BNA
Bloomberg BNA, a wholly-owned subsidiary of Bloomberg, is a leading source of legal, regulatory, and business information for professionals. Its network of more than 2,500 reporters, correspondents, and leading practitioners delivers expert analysis, news, practice tools, and guidance - the information that matters most to professionals. Bloomberg BNA's authoritative coverage spans the full range of legal practice areas, including tax & accounting, labor & employment, intellectual property, banking & securities, employee benefits, health care, privacy & data security, human resources, and environment, health & safety.
SOURCE Bloomberg BNA
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