loader image

Further Queries

Related Content

Taxand Training Tuesdays Series | Part 2

 

Asset Management: Navigating Transfer Pricing for North American Investment Structures

 

Format: Virtual
Audience: All Taxanders

Date: 5 May 2026

Time: 5:00 – 6:15 PM CET

 

Introduction

Transfer pricing in asset management is facing increasing scrutiny in North America, particularly from the IRS and the CRA. This second Training Tuesday session builds on our European-focused discussion and turns the spotlight to US and Canadian investment structures.

 

About the session

Where asset management structures intersect with transfer pricing and cross-border tax considerations in a North American context:

 

  • Who performs the key investment and management functions?
  • Where do decision‑making, personnel, and economic risks reside?
  • And how are intercompany arrangements typically structured between US and Canadian entities?

 

This session offers a practical and business-driven perspective on North American fund structures with a particular focus on how intercompany arrangements (including management, advisory, and financing arrangements) are designed, implemented, and scrutinized from a US and Canadian tax perspective. Drawing on real-life case studies and insights from North American practitioners, we will explore common structuring approaches, the associated key US and Canadian tax considerations, and areas where transfer pricing considerations arise in practice.

 

What you will cover

  • A practical overview of typical US and Canadian asset management and investment structures
  • An understanding of how value creation, functions, and risk allocation are assessed in a North American context
  • Insight into when and how transfer pricing considerations become relevant for management, advisory, and financing arrangements
  • Awareness of audit trends and common focus areas for the IRS and CRA
  • Practical observations drawn from real‑world structures and practitioner experience

 

Program (1h15)

  • Overview of typical US and Canadian investment fund structures and key stakeholders
  • Intercompany arrangements commonly seen in practice in a North American context (e.g., shareholder loans and management fees)
  • Challenges of documenting and supporting structures under IRS and CRA scrutiny
  • Case studies and practitioner insights from the US and Canada
  • Interactive discussion and Q&A

REGISTER HERE

Thank you for downloading

For similar content to our Global Guide, subscribe to our mailing list and keep up to date.

* indicates required

Newsletter

Keep up to date with news, views and insights from Taxand

Search