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August 16, 2021

Thursday, 26 August 2021 | BorderCrossings . . .With EY transfer pricing and tax professionals (1 pm ET)

Does the ‘realistic alternatives’ principle change nothing or everything in transfer pricing?

This month’s BorderCrossings webcast will discuss the “realistic alternatives” principle in transfer pricing. Our panelists will explore the principle’s evolution from various sources through its codification in the Tax Cuts and Jobs Act and incorporation into US tax treaties. They will also examine how recent practices reflect conflicting interpretations of this principle and why the role of realistic alternatives in transfer pricing cases is not as straightforward as it might first appear.

The webcast will also include a brief update on any recent (post-July) activities around the Pillar One and Pillar Two initiatives of the Organisation for Economic Co-operation and Development.

We hope you will be able to join us for this important webcast.

Date: Thursday, 26 August 2021

Time: 1:00–2:15 p.m. EDT New York/Toronto; 10:00–11:15 a.m. PDT Los Angeles/Vancouver

Registration: Register for this event.


  • Bryon Christensen, Principal, Tax Policy and Controversy Services, Ernst & Young LLP
  • Thomas Vidano, Managing Director, Transfer Pricing Controversy Services, International Tax and Transaction Services, Ernst & Young LLP


  • Mike McDonald, Managing Director, Transfer Pricing, International Tax and Transaction Services, Ernst & Young LLP

CPE credit offered: 1.4. Recommended field of study: Taxes. Learning objective: Describe the history of the realistic alternatives principle as it evolved from regulations, OECD guidance and US case law into statutory law and US tax treaties. This intermediate-level, internet-based group course has no prerequisites or advanced preparation. Final CPE award to be based on content, polling and length of participation. See CPE FAQ for more information.

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