LLM - 321F Transfer Pricing II

1 unit(s)
This course picks up where Transfer Pricing I left off, with a detailed analysis of transfer pricing issues that arise with transfers of intangible property among related parties. We will examine recent case law, regulations and international guidelines relating to the following five issues in particular: the treatment of stock option expenses; the best method analysis for valuing intangible property; the definition and nature of intangible property in the context of multinational transfers; the evolution of the US cost sharing regulations; and policy debates regarding transfers of intangible property from US multinationals to their affiliates abroad. (Offered through the LLM in Taxation and Estate Planning Programs. JD students seeking to enroll must obtain the approval of the program director.) Prerequisite(s): LLM 321D Transfer Pricing I.

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