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November 3, 2022

Thursday, 17 November 2022 | BorderCrossings with EY transfer pricing and tax professionals (1 pm ET)

US-Japan Transfer Pricing considerations

This month’s BorderCrossings webcast looks at the US-Japan transfer pricing relationship. We’re delighted to have two very special guests join us. We’ll hear from an IRS official who has spent decades reviewing, analyzing and negotiating double-tax cases and Advance Pricing Agreements (APAs) with Japan. We will also hear from a Vice President of Corporate Tax with significant experience exploring the nuances of US-Japan transfer pricing issues. To provide some context, we will begin by discussing (1) typical US-Japan related-party transactions, (2) statistics from the IRS and Organisation for Economic Co-operation and Development (OECD) and (3) Japan’s National Tax Agency’s (NTA) structure.

Specifically, we’ll discuss:

  • Typical cross-border and transfer pricing transaction considerations
  • The importance of US-Japan APAs in the Advance Pricing and Mutual Agreement Program
  • The structure of the NTA and implications for APAs
  • Potential benefits of an APA
  • Recent developments/issues
  • How taxpayers, the IRS and the NTA might view the OECD’s International Compliance Assurance Programme (ICAP)

This month’s BorderCrossings webcast will focus on detailed aspects of transfer pricing valuation. This is especially relevant for transfer pricing economists involved in valuation work. So please sharpen your pencils if this is of interest. Topics will include: (1) the power of the “differential income stream” approach under the cost sharing regulations; (2) everything you wanted to know about pre-tax versus post-tax valuation for transfer pricing (but were afraid to ask), including comparing and contrasting transfer pricing valuation and financial reporting valuation; and (3) realistic alternatives as a valuation principle.

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

Date: Thursday, 17 November 2022

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

Registration: Register for this event.


  • Dennis Bracken, Assistant Director, APMA, IRS
  • Megan Miller, Vice President, Corporate Tax, Komatsu America Corp.
  • Sho Murai, Partner, International Tax and Transaction Services – Transfer Pricing, Ernst & Young LLP
  • Thomas Ralph, Managing Director, International Tax and Transaction Services – Transfer Pricing, Ernst & Young LLP


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

CPE credit offered: 1.4. Recommended field of study: Taxes. Learning objectives: Identify some of the key theoretical and practical transfer pricing considerations relating to the United States and Japan, including double-tax cases and APAs; recognize some of the advantages/disadvantages that the United States and Japan might see in the OECD’s ICAP. This intermediate-level, internet-based group course requires no prerequisites or advanced preparation. Final CPE award to be based on content, polling and length of participation.

EY webcast managed and produced by Ernst & Young LLP’s Tax Technical Knowledge Services Group, Washington, DC: Lynn Fairfax and Barbara Kirchheimer.

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