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    July 01, 2023

    Transfer Pricing Committee

    Committee Leadership

    Chair

    Jenny Austin

    Vice-Chairs

    William H. Byrnes

    Eman Cuyler

    Heather Gorman

    Nihan Mert-Beydilli

    Brie Siciliano

    Thomas Vidano

    About the Committee

    The Vision is to establish the Transfer Pricing Committee as the most important forum for global transfer pricing issues and convey this Committee's informed comments and advice in an efficient and understandable manner to our members and the US and foreign government agencies that administer transfer pricing rules.

    The Mission of the Committee for the next several years will be:

    • (i) To keep Committee Members apprised of significant developments affecting transfer pricing,
    • (ii) To provide Committee Members with opportunities to strengthen relationships with key government officials and to influence legislative and regulatory developments involving transfer pricing,
    • (iii) To increase membership and attendance at Committee Meetings, and
    • (iv) To promote and publicize the Committee's activities to the public.

    Transfer Pricing Mentoring (TP C2B)

    TP C2B Leadership

    September 2023 Update
    After three successful years, The Transfer Pricing: From Classroom to Boardroom program (TPc2b) has returned, with a new cohort of motivated, mature students inclined toward international tax and transfer pricing. The committee is currently looking for mentors to provide the next generation of TP practitioners with exposure to & understanding of TP practices. Apply here to become a mentor by Friday, September 29. Reach out to the committee leadership, Niraja Srinivasan ([email protected]) and Elizabeth Stevens ([email protected]) with any questions.

    Chairs & Co-Founders

    • Niraja Srinivasan
    • Elizabeth Stevens

    Vice-Chair

    • Eman Cuyler

    Transfer Pricing: From Classroom to Boardroom (“TP C2B”) seeks to provide motivated students of law, economics and finance who are interested in pursuing transfer pricing careers with beyond-the-classroom insight into the real-world practice of transfer pricing by pairing them with corporate transfer pricing leaders. This rare “insider” look into how transfer pricing policies are designed and administered gives our future tax/transfer pricing professional mentees a balanced and informed view of a multinational corporation’s priorities and operations as they begin their career journeys. Corporate mentors have the opportunity to share their wisdom and experience and thereby foster the development and enhancement of the transfer pricing profession. To further slake everyone’s thirst for greater knowledge, mentors and mentees are invited to join a capstone exercise at the end of the mentoring relationship, for a sophisticated case study and networking cocktail reception. There is no cost to the students or mentors to participate in TP C2B. Willingness to learn and share the complexities of the evolving transfer pricing field is the only pre-requisite.

    Contacts: Niraja Srinivasan ([email protected]) and Elizabeth Stevens ([email protected])

    Mentors’ Roles and Responsibilities

    • Criteria: Every Mentor must be a full-time member of a corporate tax/transfer pricing team.
    • Assignment: Mentors are assigned 1-2 Mentees who are enrolled in full-time degree programs (LLM, MS Taxation or Economics) at reputable universities. Each Mentor/Mentee engagement runs for a minimum of one academic year and a maximum of two academic years.
    • Cadence: Mentors should provide their Mentees with meaningful guidance at regular intervals (> 1x month).
    • Content: Mentors have complete authority/autonomy as to what meetings and content to share with their Mentee(s). Suggested engagement topics are provided each year. 
    • No Obligation: Mentees are not interns; TP C2B is not a formal or informal employment contract between the Mentor’s company and the Mentee or his/her educational institution.
    • Oversight: An ABA TP Committee member acts as the Mentor’s program liaison, checking in with the Mentor at least quarterly to ensure that the program is proceeding smoothly.
    • Standard of Conduct: Trust, good faith and responsible actions by both parties are expected behaviors.

    Mentee Selection and Responsibilities

    • Criteria: Every Mentee must be a full-time student enrolled in a full-time degree program (law, LLM, MS Taxation or Economics) and in good academic standing. Mentees must be quick learners, good communicators and possess a high degree of maturity. Students with prior corporate employment are preferred but this is not essential.
    • Application Materials:  Prospective Mentees should submit a resume and cover letter by email to [email protected]. The application opens in September, but please don't hesitate to reach out off-cycle to discuss the program.
    • Selection Process: Mentee applications are screened by the ABA TP Committee. Selected applicants are matched with in-house practitioner Mentors, as available. 
    • Oversight: An ABA TP Committee member acts as the Mentee’s program liaison, checking in with the Mentee mid-year to ensure that the program is proceeding smoothly.
    • Standard of Conduct: The program is a valuable asset for Mentees throughout their careers, and selected students will fully understand the responsibility of engaging with a large multinational corporation’s transfer pricing function and maintaining cordiality and confidentiality. Trust, good faith and responsible actions by both parties are expected behaviors.

    Transfer Pricing Mentoring (TP C2B) Capstone at the Hybrid 2022 May Tax Meeting: Recording & Slides

    Mock APA/MAP Case Closing Meeting

    Throughout the 2021-2022 TPc2B program year, 14 pairs of student mentees and corporate tax professional mentors “met” periodically to discuss practical aspects of transfer pricing and tax for multinational corporations. The mentees gained insight into how the concepts they’re learning in class operate on the ground, and the mentors relished the opportunity to share their experience with next-generation practitioners. The program culminated in this Capstone exercise for the mentees: a mock competent authority meeting regarding a U.S. taxpayer’s request for MAP relief and a bilateral APA for its long-standing Indian tax audit. The U.S. taxpayer team must convince the APMA team and the Indian Competent authority team that its tax return position has merit and should be sustained, notwithstanding the very different arguments and position taken by the Indian tax authority. The APMA and Indian Competent Authority teams must negotiate in good faith to relieve double taxation and provide prospective certainty. What will the result be, and will it be arm’s length(ish)? As the three teams debate the issue in this 90-minute exercise, the audience and an expert panel asked questions and voted for the final result. 

    Stay in Touch with Your Committee: Listserv and Hivebrite

    Each Tax Section committee has a mailing list (listerv) and a Hivebrite community. Information about and links to both are below. 

    Listserv

    Committees share news, events, and updates through a dedicated committee listserv. As a committee member, you are welcome and encouraged to share resources, events, or ask questions to fellow committee members that are directly relevant. The listserv email address can be found below. You are automatically added to the listserv and will receive email notifications when you join a committee.   Learn more about managing your committees.

    Click the link above to view the committee listserv email address. Note: you must be logged in and a Section Member to view the address.

    Hivebrite

    In addition to listserv, each committee has a Hivebrite community. Here, committees can share meeting materials or recordings, committee newsletters, and more. All Tax Connect discussion posts have been moved over to the committee's Hivebrite community

    More Resources

    Listserv Etiquette

    A full FAQ and How to for using listserv is available here. Here are the basic dos and don'ts of using a committee listserv. The committee listserv email address is available above. Note: you have to be logged in and a Section member to view it.

    • Do reply to the listerv with substantive responses (please email “thank you” emails to the individual).
    • Do utilize the member directory to send private messages or individual messages.
    • Do reach out to Tax Staff if you have questions or issues with the community or listerve.
    • Do refer to the FAQ pages for specific problems or concerns.
    • Don’t reply all asking to unsubscribe, please follow the instructions to leave the committee.
    • Don’t share the listserv email outside of the committee.
    • Don’t post commercial messages.

    Join the Committee

    This committee is open to all Tax Section members. To join click here and then click Join Committees or follow the detailed steps below. A more detailed committee help page is available here. Not a Section Member? Join today!

    1. Click Log In in the upper right corner of this website.
    2. Log in to your My ABA account. If you do not remember your email address or password, click Need Help Logging In? and follow the instructions.
    3. Once you are logged in, click 'Hi Your Name' in the upper right then click My ABA.
    4. On the My ABA Dashboard page, click on Manage Memberships (a button toward the right with a right arrow).
    5. If you are a Section Member,  you will see Section of Taxation under Specialty Group Memberships & Committees, click Join Committees to the right. If you are not a Section member, consider joining the Section to access our committees.
    6. You will now see a list of Tax Section Committees. To join one, simply click Join next to the name of the committee. A check mark will appear to confirm you have joined. To leave a committee, simply click the check mark and you will see Join reappear indicating you are no longer a member of that committee.
    7. Joining a committee will automatically add you to the committee's listserv. Committees encourage member involvement through these committee listservs, other online platforms, and in-person at our meetings and events. 

    Have a Question or Need Assistance? Contact Staff

    If you have questions contact staff at the email addresses below and we will respond as soon as possible!