08 May 2025

Thursday, May 29 | BorderCrossings ... With EY transfer pricing and tax professionals (1 pm ET)

Continuation of OECD/G20 Pillar One update and other topics

The May BorderCrossings webcast will continue the prior webcast's discussion on some of the technical aspects of Pillar One Amount A as well as the broader historical "formulary apportionment versus arm's length" debates. Other topics include the implications of the recent IRS Generic Legal Advice Memorandum on the Commensurate-With-Income standard and the evolution of IRS and other revenue-authority interpretations of long-standing guidance.

Date: Thursday, May 29, 2025

Time: 1:00-2:15 p.m. ET New York; 10:00-11:15 a.m. PT Los Angeles

Registration: Register for this event.

Panelists

Bill Morgan, Managing Director, Transfer Pricing, International Tax and Transaction Services, Ernst & Young LLP. Bill was previously with the US Treasury Department where, among other things, he represented the United States at Working Party 6 of the OECD during the Pillar One work.

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 objectives: Review the technical aspects and history of the OECD's Pillar One, Amount A; discuss the implications of the IRS GLAM on the Commensurate-With-Income principle; outline the interpretive evolution of transfer-pricing-guidance interpretations. This intermediate level, group internet-based 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.

EY webcast managed and produced by Ernst & Young LLP's Tax Technical Knowledge Services Group, Washington, DC: Lynn Fairfax | lynn.fairfax@ey.com and Andrea Ben-Yosef | andrea.ben-yosef@ey.com

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Document ID: 2025-1014