Tax aspects of cross-border transactions in Latin American markets

• Data: 3 e 4/5
• Horário: 9h às 19h30
• Local: Hotel Unique - Avenida Brigadeiro Luis Antonio, 4700 - São Paulo/SP

Join leading experts in international tax law at this highly topical event! Topics include:

 Transfer pricing

 Capital markets - relevant tax at sector

 High executives - types of remuneration- stock plan and stock option plans / sharing mechanisms - tax aspects

 Tax aspects in mining industry

 Estate planning - wealth transfer

 Tax aspects in project

 Cost sharing - the perspective of various jurisdictions

 Investment in real state and tourism

Who should attend?

Tax lawyers, accountants, economists and corporate lawyers dealing with international tax issues in Latin America.

Conference Co-Chairs

Raquel Novais - Machado Meyer Sendacz e Opice Advogados, Brazil

Leandro Passarella - Estudio Garrido Abogados, Argentina

Organizing Committee

Alex Fischer - Carey y Cia, Chile

Leandro Passarella - Estudio Garrido Abogados, Argentina

Celso Costa - Machado Meyer Sendacz e Opice Advogados, Brazil

Luciana Rosanova Galhardo - Pinheiro Neto Advogados, Brazil

Host Committee

Eduardo Pugliese - Barros Carvalho Advocacia, Brazil

Eduardo Bocuzzi - Bocuzzi Advogados Associados, Brazil

Guido Vinci - Campos Mello Pontes Vinci & Schiller, Brazil

Manuel Sainz Orantes - Chevez Ruiz Zamarripa y Cia, Mexico

Luiz Felipe Centeno Ferraz - Demarest & Almeida Advogados, Brazil

Henrique Lopes - Koury Lopes Advogados, Brazil

Glaucia Frascino - Mattos Filho Veiga Filho Marrey Jr e Quiroga Advogados, Brazil

Jose Antonio Miguel Neto- Miguel Neto Advogados, Brazil

Monica Reyes - Reyes Abogados Asociados, Colombia

Moira Virginia Huggard Caine - Tozzini Freire Advogados, Brazil

Gustavo Brigagão - Ulhoa Canto Rezende e Guerra Advogados, Brazil

Abel Amaro - Veirano Advogados, Brazil

Horacio Bernardes - Xavier Bernardes Bragança Sociedade de Advogados, Brazil

Program

- 3/5 -

8h - 9h - Registration at Hotel Unique

9h - 9h15 - Welcome and opening remarks

Raquel Novais - Machado Meyer Sendacz e Opice Advogados, Brazil

Leandro Passarella - Estudio Garrido Abogados, Argentina

9h15 -11h Tax aspects in project financing

This panel will deal with the most relevant tax aspects in the structuring of an E&P project, from the perspective of the various jurisdictions involved. A case study will allow panelists to present the perspectives from the project companies, holding entities and the ultimate sponsors and lenders.

Session Co-Chairs

Raquel Novais - Sylvia Dikmans Loyens & Loeff NV, Netherlands

Speakers

Maria Fernanda Furtado - Trench Rossi & Watanabe, Brazil

Adriana J Vigilanza - V & Especialistas Legales Asociados, Venezuela

Olegario Soldevila - Cuatrecasas, Spain

Andrew Roycroft - Norton Rose, United Kingdom

11h - 11h15 COFFEE BREAK

11h15 - 13h Transfer pricing

There would be little disagreement with the observation that transfer pricing is crucial to the corporate tax function of multinational enterprises and has been the focal point of increasing activity by tax authorities' intent on protecting against base erosion. This session will, using case studies as a background for discussion, highlight the policy attitudes and activities of selected Latin American tax authorities in the transfer pricing area, compare them with those of the US and the OECD and examine both the impact of those developments on planning by multinational investors in the region and important strategies to address issues with regional tax authorities.

Session Co-Chairs

Luis Eduardo Schoueri - São Paulo Law University (USP), Brazil

Elinore Richardson - Borden Ladner Gervais LLP, Canada

Speakers

Fernando Tonnani - Machado Meyer Sendacz & Opice Advogados, Brazil

Juan Martin Jovanovich - Jovanovich Mazzocco & Pallaoro, Argentina

Emin Toro - Covington & Burling LLP, USA

Moises Curiel - Baker & Mackenzie, Mexico

13h - 14h45 LUNCH

14h45 - 16h30 Capital markets - Relevant tax aspects in initial public offers and bond's issuance (or fund structuring)

This panel will analyse the tax implications of companies raising capital in the form of equity or debt for investments in emerging markets' economies. The relative tax efficiency of in-country versus foreign markets for interest bearing debt and equity will be explored. Consideration will also be given to the capital markets as exit or liquidity opportunity.

Session Co-Chairs

Leandro Passarella

David Hardy - McDermott Will & Emery LLP, USA

Speakers

Gustavo Haddad - Linklaters Law Firm, Brazil

Corina Laudato - Perez Alati Grondona Benites Arntsen & Martinez de Hoz, Argentina

Manuel Garcia Diaz - Davis Polk & Wardwell, USA

Peter Adriaansen - Loyens & Loeff, Netherlands

Jessica Power - Carey & Cia, Chile

16h30 - 16h45 COFFEE BREAK

16h45 - 18h30 Cost sharing/cost center - The perspective of various jurisdictions

The distance between countries and persons grows increasingly narrower as the means of transportation, communication, and information technology develops, making their interrelations increasingly faster and intensifying both the flow of international trades and the execution of cost and expense sharing agreements. Cost and expense sharing agreements are executed among companies to share or allocate costs or expenses incurred y one of them, as these costs or expenses will eventually benefit all companies involved in the production of goods, services or rights. Based on a case study, this session will identify the tax treatment accorded to these arrangements by selected Latin American tax authorities, examining the requirements, pitfalls and risks underlying a cost sharing structure.

Session Co-Chairs

Luciana Rosanova Galhardo - Pinheiro Neto Advogados, Brazil

Stuart Chessman - International Taxes Vivendi Universal, USA (invited)

Speakers

Christine Simões - Campos Mello Pontes Vinci & Schiller, Brazil

Jose Ramon Orendain Urrutia - Chevez Ruiz Zamarripa y Cia SC, Mexico

Agnes L'Estoile Campi - CMS Bureau Francis Lefebvre, France

Antonio Russo - Baker & Mackenzie, Netherlands

19h30 Welcome cocktail and dinner

Sponsored by organizing and host committee

- 4/5 -

9h - 10h45 Estate planning - Wealth transfer and management

Regulations restricting the use of low tax jurisdictions are now more and more common throughout Latin America. The panel will analyse different strategies for holding wealth and planning wealth transfer through case studies. This will include discussing the use of trust and private foundations or other techniques.

Session Co-Chairs

Francisco Castillo - Hoet Pelaez Castillo & Duque, Venezuela

Edgar H Paltzer - Niederer Kraft & Frey, Switzerland

Speakers

Ana Claudia Utumi - Tozzini Freire Advogados, Brazil

Leonardo Costa - ABCT Asesores Legales Fiscales & Financieros, Uruguay

Juliana Cangussu Dantas - Loyens & Loeff, Netherlands

Lily Wang - Borden Ladner Gervais LLP, Canada

10h45 - 11h COFFEE BREAK

11h - 12h45 Investment in real estate and the tourism sector

The analysis will include domestic tax legislation of various jurisdictions, tax incentives for this kind of investments, including income tax treaties. The purpose is to identify, from a tax perspective, the most efficient investment vehicles in real estate and/or tourism.

Session Co-Chairs

Alejandro Torres - Chevez Ruiz Zamarripa y Cia SC, Mexico

Alejandro Escoda - Cuatrecasas, Spain

Speakers

Sabine Schutt - Xavier Bernardes Bragança Sociedade de Advogados, Brazil

Juan Eduardo Palma - Vial y Palma Abogados, Chile

Antonio Rocha Mendes - Gonçalves Pereira Castelo Branco & Associados, Portugal

Fernando de Posadas - Posadas Posadas & Vecino, Uruguay

12h45 - 14h30 LUNCH

14h30 - 16h15 High profile executives - Types of remuneration

Stock plan and stock option plans/profit sharing mechanisms - Tax aspects This panel will examine the tax treatment of alternative types of remuneration for high profile executives, including profit sharing mechanisms and stock option plans. Stock-based compensation plans and profit sharing mechanisms are playing an increasingly important role in the compensation of international executives who are becoming ncreasingly mobile. When the laws of various jurisdictions come into play, the treatment of cross boarder stock-based compensation often gives rise to complex tax issues.

Session Co-Chairs

Monica Reyes - Reyes Abogados Asociados, Colombia

Seth J Entin - Greenberg Traurig, USA

Speakers

Felipe Rocha - Pinheiro Neto Advogados, Brazil

Alejandro Barrera - Basham Ringe y Correa SC, Mexico

Jordi Dominguez - Garrigues, Spain

16h15 - 16h30 COFFEE BREAK

16h30 - 18h15 Tax aspects in the mining industry

The panel will examine tax issues that arise when a company in one jurisdiction becomes involved in mining exploration, development and production in another (South American) jurisdiction. The papers will consider holding structures, appropriate holding jurisdictions, the use of tax treaties, exploration funding, structuring joint ventures and the financing of development and production. The emphasis will be on income tax issues although reference will also be made to significant transaction taxes.

Session Co-Chairs

Alex Fischer - Carey y Cia, Chile

Douglas Powrie - Thorsteinssons LLP, Canada

Speakers

Renata Ribeiro - Companhia Vale do Rio Doce, Brazil

Cecilia Delgado Ratto - Payet Rey Cauvi Abogados, Peru

Pablo Rojas - CR&F Rojas Abogados, Bolivia

Andrew Warren - BHP Billiton, Australia (invited)

Raj Juneja - Davis Ward Philips & Vineberg, Canada (Invited)

18h15-18h30 Concluding Remarks by Raquel Novais and Leandro Passarella

Language

All working sessions and conference materials will be in English.

How to register

Investiment

*By paying the non-member fee, we welcome you as a Delegate Member of the IBA for the year in which this conference is held, which entitles you to the following benefits:

(1) Password access to certain parts of the IBA website.

(2) Receipt of IBA e-news and access to online versions of International Bar News.

(3) Pay the member rate for any subsequent conference registrations for this calendar year.

(4) Take advantage of IBA Member Rewards.

** Criteria: 65 years or over, and a member of the

IBA for 20 years or more, and no longer engaged in private practice. Full payment must be received in order to process your registration.

Frees include

 Attendance at all working sessions

 Conference materials, including any available speaker's papers submitted to the IBA before 13 April

 Access to the above conference working materials from the IBA website (www.ibanet.org) approximately seven days prior to the conference

 Lunch on 3-4 May

 Tea and coffee during breaks

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