is a speaker at the International Trade Update at Georgetown University Law Center.
During a panel discussion in Washington, DC on Friday, February 10, 2012, Mr. Sjoberg will discuss the issue of whether advance pricing agreements, as considered by the U.S. Internal Revenue Service for income tax purposes, can be used as the basis for transaction value, as considered by U.S. Customs and Border Protection ("Customs") for import duty purposes. Proper appraisement of imported merchandise is the critical element for the correct assessment of Customs duties. Determining dutiable value can be a challenging process when considering valuation issues such as, the various methods of customs appraisement, related-party transactions, and permissible additions and deductions to value. The panel will discuss specific requirements, as well as the overall topic of "harmonizing" income tax transfer pricing policies and rules with Customs related-party valuation mandates and procedures – especially in light of the "global nature" of inter-company transfer pricing and the crossborder impact of such harmonization.