Curriculum Guide · Courses

LL.M Seminar 2025 | 2 credit hours

The course is designed to provide a refresher on transfer pricing substantive rules, a comprehensive analysis of the procedural alternatives, and an understanding of the consequences of transfer pricing disputes. The course will also evaluate negotiation styles in light of current transfer pricing issues and develop a substantive/procedural strategy for dealing with transfer pricing controversy. Reading assignments will be taken from (i) Levey & Wrappe, Transfer Pricing – Rules, Compliance and Controversy (3rd Edition), (ii) the Code and Regulations (students are expected to own); (iii) Fisher and Ertel, Getting Ready to Negotiate, and (iv) materials available through the Courseware site. Because new developments related to transfer pricing arise frequently, it is likely that additional materials will be added to the Courseware site or handed out in class. Grading will be based solely on two transfer pricing controversy projects. The first project will include transfer pricing negotiations and supporting memorandums developed near the end of a transfer pricing examination-- substantive transfer pricing issue analysis, penalty analysis, negotiation strategy and negotiations. The final project will be comprehensive substantive/procedural advice on response to a client fact pattern-- substantive transfer pricing issue analysis, penalty analysis, negotiation strategy, adjustment and implementation analysis, and overall substantive substantive/procedural client advice. There is no final examination.

Recommended: Previous course in transfer pricing