Panel Discussion on International Tax Planning for the Future European Restructuring and Multi-jurisdiction Fund Management

Transcription

1 Panel Discussion on International Tax Planning for the Future European Restructuring and Multi-jurisdiction Fund Management Keynote presentation on the impact of the European Commission s common consolidated tax base proposal for Multinational companies.

2 You are cordially invited to join us for an international tax discussion on European Restructurings and Multi-jurisdiction Fund Management, featuring Switzerland as a venue for principal and fund management companies. Along with leading industry experts, U.S. Department of the Treasury Associate International Tax Counsel David Ernick will comment from the U.S. federal tax perspective, and keynote speaker Professor Lilian Faulhaber will explain how the European Commission s consolidated tax base proposal (CCCTB) will essentially reduce administrative costs for companies operating in Europe. This need-to-know discussion will be accompanied by lunch and networking opportunities. CLE / CPE credits available Tuesday, September 20, :15am - 1:00pm Boston University School of Law, Barristers Hall 765 Commonwealth Ave., Boston, MA, Reserve Your Spot! RSVP by September 13, 2011 to saskia.miller@greaterzuricharea.ch Hosted by Greater Zurich Area and Boston University School of Law In partnership with DLA Piper, WTAS, KPMG and the Boston Bar Association

3 09:15-09:30am Registration 09:30-09:45am Words of Welcome by Dan Berman, Director of the Graduate Tax Program, Boston University & Sirpa Tsimal, Director, Greater Zurich Area 09:45-10:30am Panel 1 Multi-Jurisdiction Fund Management Companies Moderator Panelists Len Schneidman, Managing Director, WTAS LLC Richard Schaul-Yoder, Partner, Foley Hoag LLP 10:30-11:15am Panel 2 European Restructuring and IP Holding Companies Moderator Panelists Alan Winston Granwell, International Tax Partner, DLA Piper LLP David Ernick, Associate International Tax Counsel, U.S Treasury Department Andreas Mueller, International Tax Partner, KPMG Joseph B. Darby III, Shareholder, Greenberg Traurig LLP Michael Hardgrove, International Tax Partner, DLA Piper LLP 11:30-01:00pm Lunch and Keynote Common Consolidated Corporate Tax Base Proposed by the European Commission Lilian V. Faulhaber, Associate Professor of Law, Boston University School of Law

4 International Tax Planning for the Future, September 20, 2011, Boston Daniel M. Berman, Professor of the Practice of Tax Law, Director, Graduate Tax Program Boston University School of Law An expert in international taxation, Daniel Berman joined BU Law in 2008 after practicing law for 25 years in Washington, DC. He worked in both the legislative and executive branches of the U.S. government, serving as legislation counsel to the Joint Committee on Taxation of the U.S. Congress and subsequently as deputy international tax counsel to the U.S. Department of the Treasury. He returned to private practice as a partner with Sutherland Asbill & Brennan LLP and Thelen Reid Brown Raysman & Steiner LLP, both in Washington. Professor Berman received his J.D., cum laude, from Harvard Law School and his A.B., magna cum laude, from Harvard College. He has taught courses in U.S. and international tax law at the International Tax Academy of the International Bureau of Fiscal Documentation (IBFD) in Amsterdam, as an adjunct professor of law at Georgetown University Law Center, and at Harvard Law School's International Tax Program. Joseph B. Darby III, Shareholder, Greenberg Traurig LLP Joseph B. Darby III is a shareholder in the Boston office of Greenberg Traurig LLP, and has been admitted to the practice of law in Massachusetts since He is a tax attorney who focuses his practice on business and transactional tax law, and he advises a wide variety of corporations and high net-worth individuals on tax and legal aspects of business and real estate activities, and represents these taxpayers before federal and state taxing authorities. Mr. Darby has been the recipient of numerous journalism and writing awards, and has authored two books and more than 1,000 articles published in such diverse publications as The Tax Lawyer, Worth Magazine, Venture Capital Magazine, Banker & Tradesman, Mass High Tech, Hemispheres Magazine, The Boston Globe, The Boston Herald, among others. David Ernick, Associate International Tax Counsel, U.S Treasury Department David Ernick is Associate International Tax Counsel at the U.S. Treasury Department. His responsibilities include tax treaties, trade agreements, regulatory guidance, and legislative matters. He has also represented the United States at the OECD in the areas of harmful tax competition and transfer pricing, and served as the Chair of the Working Party No. 6 Special Session on Business Restructurings. Prior to joining Treasury in 2004, Mr. Ernick practiced as a tax associate at Cravath, Swaine & Moore in New York and at Wilmer, Cutler & Pickering in Washington. He has also clerked on the U.S. Tax Court and the U.S. Court of Appeals for the Eleventh Circuit and has taught corporate taxation as an adjunct professor at George Mason University Law School.

5 International Tax Planning for the Future, September 20, 2011, Boston Lilian V. Faulhaber, Associate Professor of Law, Boston University School of Law Associate Professor Lilian V. Faulhaber came to BU from Harvard Law School, where she was a Climenko Fellow and Lecturer on Law. Her primary academic interests are federal income tax, European Union law, tax policy, international tax, international law, and comparative law. She clerked for Senior Judge Robert E. Keeton and Judge William G. Young, both on the U.S. District Court for the District of Massachusetts, and was an associate at Cleary Gottlieb Steen & Hamilton LLP in New York. She is a graduate of Harvard College, Cambridge University and Harvard Law School, where she was the editor-in-chief of the Harvard International Law Journal. Alan Winston Granwell, International Tax Partner, DLA Piper LLP Alan Winston Granwell is an international tax partner resident in DLA Piper's Washington, DC office. Mr. Granwell s practice encompasses representing multinational corporations on cross-border planning, to include acquisitions, dispositions and business restructurings, IP migrations, services arrangements, repatriation planning, international insurance, international transportation, cross-border leasing, transfer pricing and the use of bilateral tax treaties. He also advises high-net-worth individuals on cross-border tax planning and structuring. Mr. Granwell has been named one of the world's leading tax lawyers in independent studies of tax law professionals worldwide, including studies published by Chambers & Partners, Euromoney Publications, Expert Guide to the World's Leading Tax Advisers, The Best Lawyers in America, The Best of the Best USA 2008 and Who's Who Legal, and also has been named as one of the world's leading transfer pricing advisers in the Euromoney Guide to The World's Leading Transfer Pricing Advisors. Michael Hardgrove, International Tax Partner, DLA Piper LLP Mike Hardgrove is in the Boston office of DLA Piper. His practice provides strategic consulting for international structuring and intangible transaction services to numerous public and private companies with operations throughout the world. Mr. Hardgrove concentrates on global business strategies, using a process of assessing international tax and operating cost exposures and then designing structures and transaction flows for cost efficiency and value enhancement. Primary objectives are to reduce the cost of capital and lower the overall effective tax rate. Mr. Hardgrove was with PricewaterhouseCoopers for more than 20 years, working in Brussels, San Jose/San Francisco and Seattle. He served as PwC s US leader for global structure alignment and national tax leader of the industrial manufacturing industry sector. Mr. Hardgrove has taught international taxation courses as an adjunct faculty member in the law school LL.M. programs at both the University of Washington and Golden Gate University. He has written articles on international taxation, intangible property planning, global business issues, cross-border income taxation and planning for global expansion for the Journal of Accountancy, International Tax Review, CCH, the California Bar Journal and the Canadian Tax Foundation, as well as PwC s Mastering the Intellectual Property Life Cycle.

6 International Tax Planning for the Future, September 20, 2011, Boston Andreas Müller, International Tax Partner, ICT Country Leader Switzerland, Head of the Swiss/US Market Group and the Swiss TESCM Group, KPMG Andreas Müller joined KPMG in 1999 and is a permanent member of the Global International Corporate Tax ( GICT ) EU Roundtable Group where he represents Switzerland in six country visits annually. Andreas works for national and international groups across different industries and is an expert for Swiss inbound and outbound tax planning. He has experience in leading and implementing international and multidisciplinary projects, in particular setting up of IP and procurement companies, Principal companies and negotiating Swiss Tax Holidays as well as global restructuring projects as inversion projects ; additionally he has acted as the tax lead for transactions such as the split of listed Swiss groups and the acquisitions and disposals of substantial parts of listed Swiss groups. Mr. Müller is a graduate of the University of Zurich with a Master s in Law. Richard Schaul-Yoder, Partner, Foley Hoag LLP Richard Schaul-Yoder is former chair of the Taxation Department at FOLEY HOAG LLP and a member of the firm s Investment Advisers and Private Investment Funds Group. The Group s clients include managers forming their first funds and mature investment groups managing billions of dollars in multiple domestic and international strategies. Mr. Schaul-Yoder has particular experience in tax planning for investment managers and the hedge funds and other investment funds they manage, as well as in international tax planning. In the investment fund arena, he provides tax planning for onshore and offshore funds, master-feeder and multi-class partnership structures to accommodate investors' varying tax profiles; and various carried-interest arrangements for managers and affiliates. In the international arena, he regularly structures both inbound and outbound investments, including derivative instruments, as well as inbound and outbound mergers and acquisitions. Mr. Schaul-Yoder is a member of the tax committees of the International Bar Association and the International Fiscal Association, and has served as chair of various subcommittees for the American Bar Association Tax Section s Committee on U.S. Activities of Foreigners and Tax Treaties. Len Schneidman, Managing Director, WTAS LLC Len Schneidman has over 40 years of experience in international taxation. His work includes counseling clients on structuring and operation of private investment funds, advising high net worth foreign investors on U.S. investments and activities, and helping U.S. and non-u.s. corporate clients with tax-efficient structuring of their business operations. Len has had significant involvement with issues of U.S. international tax policy and tax reform, including chairmanship of the ABA's U.S. Activities of Foreigners and Tax Treaties Committee and co-chairmanship of the ABA s Task Force on International Tax Reform. Len is a frequent speaker, presenting annually at the NYU Federal Tax Institute and at private equity and hedge fund tax programs. A prolific writer on tax matters, Len is author of the treatise, "U.S. Taxation of Foreign Portfolio Investors: A Practical Guide to Taxation in the U.S. Capital markets" and has edited a Practicing Law Institute treatise on Sovereign Wealth Funds - A Legal, Tax and Economic Perspective. Before joining WTAS, Len practiced with several large law firms, including a position as tax department Chair.

7 International Tax Planning for the Future, September 20, 2011, Boston Sirpa Tsimal, Director US, Greater Zurich Area Inc. Sirpa Tsimal is the director for North America at Greater Zurich Area Inc, an Investment Promotion Agency, representing the economic region of Zurich, Switzerland. In this position, Ms. Tsimal oversees marketing activities for the organization in the US & Canada since 2006, with a business acumen in consulting US companies on global expansion strategies and Switzerland. Prior to this, Ms. Tsimal was a key account manager with Strategic Ventures & Research, a boutique venture advisory firm and was also employed at the News Center of the United Nations in New York. Ms. Tsimal serves on the board of the Swiss-American Chamber of Commerce in New York as the Co-founder of the Young Professional Committee (YPC). And as a Swiss country specialist she offers cross-cultural training sessions to executives and expats. As a native Swiss, Ms. Tsimal relocated to the US in Prior to her relocation, Ms. Tsimal held various positions in the field of media research & communications at the Center of Enterprise Science (ETH Zurich) and Pestalozzianum, an educational foundation. Ms. Tsimal graduated from University of Zurich with an MA in Communications and International Law in In 2000, she spent one semester abroad at Rhodes University, South Africa to broaden her skills in media. Ms. Tsimal is fluent in German, English and Finnish. Saskia Miller, Project Manager, Greater Zurich Area Inc. Saskia Miller is the Project Manager for North America at Greater Zurich Area Inc, the official investment promotion agency of the economic region of Zurich, Switzerland. Ms. Miller advises growing companies on European expansion and on Switzerland as a business location, and manages Greater Zurich Area Inc. events in various regions of the US. With a particular expertise in U.S. - European exchange, Ms. Miller has collaborated with international teams in the development and execution of cross-border projects and events since Her past work includes managing programs for New York University and the New York City Department of Parks & Recreation, producing art exhibitions, and conducting market research for boutique branding firm The Branding Clinic. Ms. Miller is also co-founder of PenTales, a cultural venture with an active presence in 25 cities and over 10,000 participants. Ms. Miller has an M.A. in Communications from the Free University of Berlin and a B.A. in Cross-Cultural Dialogue from NYU. As a German and American dual citizen, she is native fluent in German and English, has an advanced knowledge of French, and has lived in Berlin and in New York. The Greater Zurich Area is the official Investment Promotion Agency for the region of Zurich, Switzerland and provides a free and confidential advisory service. We assist foreign companies in evaluating our region for their expansion / relocation projects. We provide the most useful analysis on the Swiss business environment and assist step-by-step in establishing an operation in Switzerland (Advising on taxes and corporate structures, labor laws, recruitment, infrastructure and real estate). In addition, we facilitate contacts with government officials, business networks and service providers in the area.

8 CPE Information DLA PIPER LLP (US) Invites you to attend a presentation on Panel Discussion on International Tax Planning for the Future European Restructuring and Multi-jurisdiction Fund Management September 20, :15 to 1:00 p.m./est This presentation covers various aspects of European Restructurings and Multi-jurisdiction Fund Management, featuring Switzerland as a venue for principal and fund management companies. Along with leading industry experts, U.S. Department of the Treasury Associate International Tax Counsel David Ernick will comment from the U.S. federal tax perspective, and keynote speaker Professor Lilian Faulhaber will explain how the European Commission s consolidated tax base proposal (CCCTB) will essentially reduce administrative costs for companies operating in Europe. LEARNING OBJECTIVES: What is a BR (Business Restructuring) and Why Engage in a BR Why Switzerland is Ideal for a Principal or a Fund Management Company US, OECD and local issues relating to BRs and IP European Commission s consolidated tax base proposal (CCCTB) DELIVERY METHOD: Live Program PROGRAM LEVEL: All Levels PREREQUISITES: Previous Experience with Cross-Border Transactions ADVANCED PREPARATION: Knowledge of International Business EAST\ Earn 3.0 CPE Credits To register for this free program and for more information regarding administrative policies such as complaint, please contact Melody Burton, Professional Development Department at DLA Piper LLP (US) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website:

9 MCLE Information California: This activity has been approved for Minimum Continuing Legal Education credit by the State Bar of California in the amount of 2.5 hours in the General category. DLA Piper certifies that this activity conforms to the standards for approved education activities prescribed in the rules and regulations of the State Bar of California governing minimum continuing legal education. New York: This transitional and nontransitional continuing legal education program has been approved in accordance with the requirements of the Continuing Legal Education Board for a maximum of 3.0 credit hours, of which 3.0 credit hours can be applied toward the Professional Practice requirement. Please note that CLE credit is available for newly admitted attorneys. New Jersey: This program has been approved by the Board on Continuing Legal Education of the Supreme Court of New Jersey for 3.0 hours of total CLE credit. Of these, 3.0 qualify as hours of credit toward the General category. CLE credit will be applied for in other states where DLA Piper has an office except in Minnesota, North Carolina, and Pennsylvania. EAST\