Partners John Lehrer and Brian Davis led the session titled “Transfer Pricing Under Section 482, Parts 1 and 2,” at TEI’s 2026 U.S. International Tax Course, Aug. 3-7, 2026, in Seattle, Washington. The session provided an overview of U.S. transfer pricing rules, regulations and methods under section 482, beginning with an overview of the critical nature of transfer pricing to multinational enterprise operations and following with a detailed discussion of the U.S. rules, the multilateral nature of the current transfer pricing environment and recent transfer pricing case law. More than 135 tax professionals from companies located throughout the U.S. attended the session.
