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Complexities, Discontinuities, and Unintended Consequences of U.S. International Tax Rules: Options for Change

San Francisco, CA

Rocco Femia will speak at "Complexities, Discontinuities, and Unintended Consequences of U.S. International Tax Rules: Options for Change" at the UC Law SF Center on Tax Law on September 12, 2024. Femia will present the session "Transfer Pricing." His session will focus on whether the regulatory arm's length standard should be incorporated into the statute, whether the special statutory rules applicable to intangible property should be restated or reconsidered in light of developments, whether ancillary transfer pricing rules should be better coordinated with section 482, and whether other changes should be considered in light of developments in U.S. law or international guidelines.