Скачать или смотреть What is Transfer Pricing? Week 1 Lecture 3 Texas A&M International Tax Risk Management curriculum

Pre-recorded lecture within a series of lectures each week that help to inform and contextualize the week's case study for the student teams. Want to learn more? https://law.tamu.edu/distance-educati...

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 22 Friday at 9am – 10:30am (presentations, peer feedback)
• Read textbook chapter 40 (William Byrnes' Lexis treatise in the Canvas course folder)

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
Jan 29 Friday at 9am – 10:30 (presentations, peer feedback)
• Read textbook chapter 5 then read chapter 4
• Review the analysis within the comparables cases (watch videos and review slides)
• Prepare team approaches for the case study of the Christmas Tree scenario.

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
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 the 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
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 the textbook regarding coffee, technology, tobacco).
• Team’s prepare the Case Study.

Week 6 Feb 23 Best Method – Snowin’ and Blowin’ case study
Feb 23 Tuesday at 9am – 10:30am
Feb 26 Friday at 9am – 10:30 (presentations, peer feedback)
• Read textbook chapters 15 and 16
• Watch Dr. Eden's videos.

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
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)
A local investor steps in who can help with project viability, but requires a stake in the business.. At the local investor’s intervention, the company is given a PPA (power purchase agreement) to build a $450 mn power station. In week 13, the investors find out that the state-owned off-take customer is not utilizing the full capacity of the FSRU

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

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