Program Highlights:
• Explain economic models for valuing employee stock options and review the controversial tax and GAAP issues
• Describe how tax transfer pricing for intangibles fits in with global investment strategies of multinational firms
• Learn to carefully word intercompany license agreements to minimize controversy with tax authorities
• Learn to apply valuation methods for intangibles that avoid significant bias
• Reconcile tax and GAAP treatments of intangible valuations
• Provide perspectives on the use of in-house versus independent economists in transfer pricing projects
• Explore how Sarbanes-Oxley affects planning for and administration of transactions involving intangibles

Tax consultants and tax personnel of multinational corporations who deal, directly or indirectly, with transfer pricing valuation issues, and financial personnel with backgrounds in accounting, law and/or finance will gain insight into this complex area.

This day-and-a-half symposium reviews controversial economic and legal issues associated with tax transfer pricing for intangibles and employee stock options. It is increasingly important for tax practitioners to have a basic understanding of many complex transfer pricing and valuation issues associated with intangibles. Since tax practitioners are often brought into or required to manage complex controversies, they cannot afford to leave all details to outside experts. This symposium helps develop the technical background that will be useful for tax practitioners in today's complex global economy.

Reading Materials

A reading package of conference materials will be provided.

About TPVI

The Transfer Pricing Valuation Institute aims to promote understanding of transfer pricing as a taxation issue, with an emphasis on educating practitioners on the controversial economic issues surrounding transfer pricing, valuation and the arm's length standard. The Institute conducts conferences and provides research on relevant transfer pricing and valuation issues.

Program Chairman

David F. Andrade, Ph.D., is a recognized expert in the economics of transfer pricing and intellectual property and has been engaged as an expert consultant on many highprofile transfer pricing and tax valuation issues associated with widely recognized multinational firms.

Dr. Andrade is director of the Transfer Pricing Valuation Institute at the University of Washington School of Law Graduate Program in Taxation, where he teaches courses and performs research in transfer pricing, taxation/valuation of intangibles and economic policy issues related to intellectual property. He received his Ph.D. in economics from the University of California at Davis and has testified in court as an expert witness.

Featured Speaker

Micheal C. Durst, Esq., is a partner with King & Spalding's Washington, D.C. and London offices. Mr. Durst is a recognized expert on transfer pricing and other international tax issues. Mr. Durst served as the director of the IRS Advance Pricing Agreement Program and as the coleader of the national transfer pricing practice with the professional services firm of PricewaterhouseCoopers.

Mr. Durst was named in Euromoney's "The Best of the Best 2001" as one of the leading transfer pricing attorneys in the United States and is also listed in the 2003-2004 edition of The Best Lawyers in America. He received his J.D. from the University of California at Berkeley, and also holds a master’s degree in economics from MIT, and an LL.M. from Harvard Law School.

Other Speakers

David Chamberlain, Esq. - Mr. Chamberlain is an independent Silicon Valley consultant who specializes in accounting and tax treatment of employee stock options, transfer pricing and international tax issues.

David Guenther, Microsoft Corporation - Mr. Guenther is the in-house transfer pricing economist for Microsoft. He has worked at Ernst & Young offices in Washington, D.C. and San Jose, and was previously the in-house transfer pricing economist at Cisco Systems.

Toussaint Myricks, Esq., Vulcan, Inc. - Mr. Myricks is chief-in-house patent counsel for Vulcan, Inc. He is an expert on the protection and management of intellectual property rights. He also performs research and regularly speaks on such issues.

Toru Nakamura, Ph.D. - Dr. Nakamura is an independent economist advising on Japanese issues in transfer pricing and valuation of companies, and on market and policy developments in Japan.

Avinash Verma, Ph.D. - Dr. Verma is an independent economist who specializes in option pricing and valuation issues. Dr. Verma teaches related courses at the University of California at Berkeley.

10 General CLE credits approved. For more information regarding CLE credits, contact UW CLE at 206-543-0059.

Refunds are available up to five business days prior to the program. In lieu of refund we encourage participants to send a substitute. Please notify UW CLE of any requests for refunds or substitutions. All cancellations are subject to a $30 handling charge.

To request accommodations for the disabled, please contact the office of the ADA coordinator at (206) 543-6450 (voice); (206) 543-6452 (TTY); (206) 685=7264 (fax); or dso@u.washington.edu (e-mail).