What Japanese Companies Need to Know: Lunch and Learn on IRS Transfer Pricing Enforcement

Recent changes to U.S. transfer pricing enforcement place companies at greater risk of transfer pricing adjustments and penalties. Our presentation will cover changes to the IRS audit approach, why the IRS litigation results are improving, and how IRS changes to its penalty approach make companies less protected from penalties.  We will explain how these trends affect Japanese companies in the U.S., and how they should re-evaluate transfer pricing policies and documentation to reduce risk. Our speakers have experience with the IRS and Big 4 firms, and they will explain in English and Japanese. After the seminar, we will have an opportunity to answer any questions.

Main Speakers 

Steven Wrappe 

Tax – Managing Director, National Technical Leader, Transfer Pricing, Grant Thornton

Steve Wrappe is Grant Thornton’s Transfer Pricing Technical Leader in its Washington National Tax Office. He is a globally-recognized transfer pricing expert, with over 25 years of experience in transfer pricing planning, compliance and controversy for large multinational clients. During that time, he has been a Senior Attorney with the IRS Advance Pricing Agreement (APA) Program, a partner with a global law firm, and the transfer pricing controversy leader at Big Four Firms.

Masatake Kuramoto

Managing Director, NERA Economic Consulting

Masatake (Masa) Kuramoto is an accomplished and well-respected transfer pricing expert with over 25 years of experience in transfer pricing strategy, documentation, planning and implementation, disputes, and advance pricing agreements (APAs). 

Other speakers including Samit Shah and others Japanese company leaders may also participate.