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International Tax Issues for Oil & Gas

Contains material from Dec 2015

International Tax Issues for Oil & Gas
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Session 1: Transfer Pricing Enforcement and Defense - A discussion of the U.S. transfer pricing enforcement environment with respect to the oil and gas industry, including current IRS initiatives, litigation, and recent APA and competent authority experience; plus an examination of the transfer pricing issues affected by the OECD BEPS project, with special focus on intangibles as well as country-by-country reporting and taxpayer efforts that comply and defend transfer pricing determinations in this environment.
 
Session 2: Foreign Tax Credit Developments - A discussion and analysis of key foreign tax credit issues affecting the oil and gas industry, including ODLs and the effect of changing from deducting to crediting foreign taxes (and the resulting impact on the availability of credit), current foreign tax credit guidance, and more.

Includes: Audio Slides


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1. Transfer Pricing Enforcement and Defense (Dec 2015)

Steven C. Wrappe, John C. Hughes, Paul M. Schmidt, Andrew S. Sliwa, Kathrin Zoeller

1.25 0.00 0.00
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(mp3)
76 mins
(pdf)
29 pgs
Session 1 —76 mins
Transfer Pricing Enforcement and Defense (Dec 2015)

A discussion of the U.S. transfer pricing enforcement environment with respect to the oil and gas industry, including current IRS initiatives, litigation, and recent APA and competent authority experience; plus an examination of the transfer pricing issues affected by the OECD BEPS project, with special focus on intangibles as well as country-by-country reporting and taxpayer efforts that comply and defend transfer pricing determinations in this environment.

Originally presented: Nov 2015 Oil and Gas Tax Conference

Steven C. Wrappe, KPMG LLP - Washington, DC
John C. Hughes, Internal Revenue Service - Washington, DC
Paul M. Schmidt, BakerHostetler - Washington, DC
Andrew S. Sliwa, Ernst & Young LLP - Chicago, IL
Kathrin Zoeller, Weatherford - Houston, TX

Show session details

2. Foreign Tax Credit Developments  (Dec 2015)

Ujwala (UJ) Bhandari, Richard Chewning, David E. Coe, John Fiorito, Edward C. Osterberg Jr.

1.25 0.00 0.00
Preview Materials

Download session materials for offline use

(mp3)
70 mins
(pdf)
10 pgs
Slides
(pdf)
9 pgs
Slides
(pdf)
8 pgs
(pdf)
12 pgs
Session 2 —70 mins
Foreign Tax Credit Developments  (Dec 2015)

A discussion and analysis of key foreign tax credit issues affecting the oil and gas industry, including ODLs and the effect of changing from deducting to crediting foreign taxes (and the resulting impact on the availability of credit), current foreign tax credit guidance, and more.

Originally presented: Nov 2015 Oil and Gas Tax Conference

Ujwala (UJ) Bhandari, Former Director of Tax, Tenaris - Houston, TX
Richard Chewning, Internal Revenue Service - Washington, DC
David E. Coe, Chevron Services Company - Houston, TX
John Fiorito, Ernst and Young, LLP - Houston, TX
Edward C. Osterberg Jr., Mayer Brown LLP - Houston, TX