How To Plan A Tax-Compliant Estate Planning

Transcription

1 IFZ-Conference International Estate Planning Summit 2015 Tax-Compliant Estate Planning through Switzerland and Liechtenstein for Argentinian, Brazilian, Mexican and Colombian High Net Worth Individuals and Corporations 22 September 2015, 8.45 a.m p.m. 21 September 2015, 6.45 p.m. Gala Dinner at Romantik Seehotel Sonne, Küsnacht Institute of Financial Services Zug IFZ

2 International Estate Planning 2015 Target Groups Employees, family offices, bankers, tax consultants, trustees, fund managers, asset managers, auditors, lawyers, government officers, practitioners, consultants, accountants in financial market industries, financial intermediaries and investors, in particular from Argentina, Brazil, Mexico, Colombia, Switzerland and Liechtenstein. Time Tuesday, 22 September 2015, a.m p.m. A gala dinner will be held the evening before, on 21 September 2015, 6.45 p.m. Costs CHF 690., per person, including conference materials, lunch and apéro. CHF 940., per person including gala dinner on the evening of 21 September Applications are open until 11 September 2015 Lucerne School of Business Institute of Financial Services Zug IFZ Grafenauweg Zug Switzerland T F ifz@hslu.ch Registration will be firstcome, first-served and is strictly limited to 70 participants. Information Concept The aim of this International Estate Planning Summit is to discuss and analyse important aspects in relation to cross-border wealth structuring for a number of selected countries. The Conference will focus mainly on aspects of tax law, family law, inheritance law, property law and contract law that should be considered in tax and wealth planning for high net worth individuals and corporations. Outstanding practitioners and scholars will explore structuring ideas for individuals and corporations domiciled in Argentina, Brazil, Mexico, Colombia, Switzerland and Liechtenstein, including tax-compliant uses of trusts, foundations, partnerships and collective investment schemes. Speakers Tatiana Antunes Valente Rodrigues, Enseada Partners, Brazil; Javier Ayuso, Bruchou, Fernández Madero & Lombardi, Argentina; Prof Dr João Dácio Rolim, Rolim, Viotti & Leite Campos, Brazil; Frederico de Almeida Fonseca, Rolim, Viotti & Leite Campos, Brazil; Dr Richard Gassmann, Baker & McKenzie, Zurich; Mónica Inés Hernández Gómez, Godoy & Hoyos Abogados, Colombia; Prof Dr Hans Rainer Künzle, Kendris AG, Zurich and University of Zurich; Ezequiel Lipovetzky, Bruchou, Fernández Madero & Lombardi, Argentina; Irma Mosquera, Hamelink & Van den Tooren, the Hague; Roland A. Pfister, Lucerne University of Applied Sciences and Arts and Badertscher Rechtsanwälte Zurich/Zug; Manuel E. Tron, Manuel Tron S.C., Mexico; Dr René Vallaster, Allied Finance, Vaduz; Dr Ernst J. Walch, Walch & Schurti Attorneys at Law, Liechtenstein Moderation Chantal Raymond, David Carrie LLC, New York Place The Summit takes place at the Romantik Seehotel Sonne, Seestrasse 120, 8700 Küsnacht/Lake Zurich ( Either 10 minutes by taxi from Zurich main station or 5 minutes walking distance from Küsnacht train station.

3 Programme a.m. Introduction and Welcome Roland A. Pfister a.m. Estate Planning in Switzerland and Liechtenstein Prof Dr Hans Rainer Künzle a.m. Switzerland and Liechtenstein as Excellent Jurisdictions for Tax-Compliant Estate Planning Solutions for Argentinian, Brazilian, Mexican and Colombian High Net Worth Individuals and Corporations Roland A. Pfister a.m. Coffee break a.m. Asset Protection as a Key Element of Estate Planning Dr René Vallaster, Dr Ernst J. Walch, Prof Dr Hans Rainer Künzle, Dr Richard Gassmann a.m. Estate Planning Solutions for Mexican High Net Worth Individuals and Manuel E. Tron a.m. Lunch p.m. Estate Planning Solutions for Colombian High Net Worth Individuals and Irma Mosquera, Mónica Inés Hernández Gómez p.m. Estate Planning Solutions for Argentinian High Net Worth Individuals and Javier Ayuso and/or Ezequiel Lipovetzky p.m. Coffee break p.m. Estate Planning Solutions for Brazilian High Net Worth Individuals and Frederico de Almeida Fonseca and/or Prof Dr João Dácio Rolim, Tatiana Antunes Valente Rodrigues p.m. Exchange of Information under Automatic Exchange of Information, Double Tax Conventions, Tax Information Exchange Agreements, FATCA, Rubik Agreements and Action Plan on Base Erosion and Profit Shifting (BEPS) : Implications for Tax-Compliant Wealth Planning Strategies for High Net Worth Individuals and Corporations Roland A. Pfister, Manuel E. Tron, Javier Ayuso and/or Ezequiel Lipovetzky, Prof Dr João Dácio Rolim and/or Frederico de Almeida Fonseca, Irma Mosquera p.m. Closing Speech Roland A. Pfister p.m. Apéro

4 Special thanks go to our sponsors Contact Lucerne School of Business Institute of Financial Services Zug IFZ Grafenauweg 10 P.O. Box Zug Switzerland T F ifz@hslu.ch blog.hslu.ch/ifz

5 Speakers Tatiana Antunes Valente Rodrigues, Enseada Partners, São Paulo, graduated from the University of São Paulo (USP) Law School. She has experience of over 12 years in family and probate law, estate and succession planning, mainly for high & ultra high networth individuals, assisting them in Brazil and abroad. She is an Advisor at Enseada Partners, a Brazilian Multi Family Office and started her carreer in Wealth Advisory / Estate Planning and Estate at Souza, Cescon, Barrieu and Flesch Advogados and Freitas e Leite Advogados. She has written several publications related to family and succession law. Javier Ayuso, Bruchou, Fernández Madero & Lombardi, Buenos Aires, graduated with honors from the Law School of the Argentine Catholic University in 1988, obtained a Master of Science in Finance from the University of Illinois at Urbana-Champaign (US) in 1993 and completed a Master in Business Administration from the Belgrano University (Argentina) in Since he joined the firm in 1993, he has specialized in mergers & acquisitions, venture capital investment and wealth and succession planning. He has published various articles and commentaries to case-law in connection to the utilization of trusts, foundations and other wealth management structures. Prof Dr João Dácio Rolim, Rolim, Viotti & Leite Campos, São Paulo, graduated from the University of São Paulo (USP) Law School. He has an LL.M. in International Tax Law from the London School of Economics (LSE) and a PhD in Tax Law from the Federal University of Minas Gerais (UFMG). He is a tax lecturer at the Fundação Getulio Vargas (FGV SP and Rio) and a Researcher in International Trade Law, Taxation and Human Rights at Queen Mary, University of London. He started his tax career at KPMG and PwC and founded the law firm Rolim, Viotti & Leite Campos in 1993, with five offices in Brazil and one in Lisbon (Portugal). His expertise is in international taxation in Brazil and he also deals with complex litigation tax cases. He is Director of the AIBAT (Iberian-American Tax Arbitration Association) and of the IFA Brazilian branch (ABDF). Frederico de Almeida Fonseca, Rolim, Viotti & Leite Campos, São Paulo, studied Law at the Catholic University of Minas Gerais (PUC), Brazil. He holds an LL.M. in Tax and Corporate Law from the Milton Campos University and an LL.M. in Regulatory Law from the Fundação Getulio Vargas (FGV), Rio de Janeiro, Brazil, with a focus on the taxation of the Brazilian Energy Sector. He started his career with PwC in 1997 where he became a tax manager in In 2004 he was invited to join Rolim Viotti & Leite Campos Attorneys at Law, with five offices in Brazil and one in Lisbon (Portugal), where he became a Tax Partner in He is now the Head of the Tax Consulting department of Minas Gerais branch. His professional focus is on national and international tax and estate planning as well as M&A transactions. He is a tax lecturer in many LL.M. Programs in Brazil such as FGV, PUC and at the Brazilian Bar Association (OAB). He joins both Corporate and Regulatory Commissions at the Brazilian Bar Association and he is a member at the Fiscal Studies Institute (IEFi), Brazil. Dr Richard Gassmann, Baker & McKenzie, Zurich, heads the Firm s Dispute Resolution Practice Group in Zurich, and serves as member of the Private Banking Practice Group. He has extensive experience in dispute resolution, particularly on cross-border litigation and international arbitration. He also advises clients on international private law, complex multijurisdictional structures, debt enforcement, restructuring and bankruptcy law. In addition to his practice, he has authored several articles for the Journal of International Taxation, Europa Institut Zürich, European Legal Development Bulletin and other publications. He is a member of STEP, the Swiss Arbitration Association, the Société Suisse de Droit Internationale and the Association LP. He has represented numerous individuals and companies on international arbitration proceedings, specifically in ICC and UNCITRAL. Working collaboratively with the Private Banking groups in Geneva, Zurich and London, he also advises Swiss and foreign clients on trust and estate issues, particularly in relation to conflict of laws, compliance and litigation matters.

6 Mónica Inés Hernández Gómez, Godoy & Hoyos Abogados, Bogotá, Colombia, graduated in Law at Pontificia Universidad Javeriana and with an Advanced LL.M. in International Tax Law at Leiden University (the Netherlands). She joined the firm in 2006 and currently works as Tax Director Associate and leader of the transfer pricing area. She has given advice to clients in tax matters in general, tax planning, tax matters specifically in estate planning for individuals and corporations. She has also participated in the tax litigation department, defending clients in front of the tax authorities and the Colombian courts. She currently teaches the Tax Law course of the bachelor program in Law at Pontificia Universidad Javeriana. She has also taught at the postgraduate (specialization) program in Tax Law. Prof Dr Hans Rainer Künzle, Kendris AG, Zurich and Universitiy of Zurich studied Law and Economics at the University of St. Gall. He was a Main-Assistant at the University of Zurich when he wrote his second thesis (Habilitation). In 1989/1990 he was a Visiting Scholar at the Boalt Hall Law School of the University of California, Berkeley. He started his career with KPMG in 1997 and became Partner in In 2005 he participated in a management buyout of KPMG Private, which was renamed Kendris Private Ltd. and subsequently Kendris Ltd. His professional focus is on estate planning and estate administration in an international context. He is known for his Bernese Commentary on the Swiss Executor (Willensvollstrecker). He is a co-editor of the Law Review Successio. Ezequiel Lipovetzky, Bruchou, Fernández Madero & Lombardi, Buenos Aires, received a law degree from the Law School of the University of Buenos Aires in He also made postgraduate studies in Tax Law from the University of Buenos Aires School of Economics in Prior to joining the firm in 2008, he was a member of Baker & McKenzie and of Marval, O Farrell & Mairal, among others, acting mainly in tax consulting. He specializes in tax law, a subject in which he has given and attended several courses, and in which he legally advises most of the firm s clients. He has provided tax counsel in local and international deals, and has been involved with different clients of the firm in capital markets, project finance, national and international tax planning, M&A, general finance and general corporate advice activities. Furthermore, he has been a speaker in Tax seminars, both in Argentina and abroad, and has written several articles on tax matters in specialized publications, magazines and newspapers. Irma Mosquera, Hamelink & Van den Tooren N.V., The Hague, obtained her PhD (cum laude) from the University of Groningen in She works as a tax advisor at Hamelink & Van den Tooren in the Netherlands specializing in international tax law. She also works as a post-doctoral research fellow on issues related to tax treaties and is a Scientific Researcher of the Global Tax Treaty Commentaries at the International Bureau of Fiscal Documentation in Amsterdam. She lectures in the Bachelor of Law Program at The Hague University in the Netherlands. She also participates in the DeStat Group, a research group of researchers of seven countries studying sustainable tax governance in developing countries in the era of global fiscal transparency. She has worked as a tax advisor at PwC in the Netherlands and as an assistant professor at the University of Utrecht. She has been a visiting professor in international tax law and tax law and development at the University of Florida (Gainesville) and two universities in Colombia. She is a member of the International Fiscal Association, the Netherlands Comparative Law Association and the National Tax Association (the United States). She has published several articles. Roland A. Pfister, Lucerne University of Applied Sciences and Arts and Badertscher Attorneys-at-Law Zurich/Zug, studied law at the Universities of Neuchâtel and Granada. After the completion of his law degree, he worked for an international law firm in Belgium and a leading investment bank in Zurich. Then, he joined the tax department of one of the «Big Four» firms in Zurich/Geneva. In addition, he holds an Executive MBA in Wealth Management and was a Visiting Researcher at Harvard Law School. From 2011 to 2014, he worked at a law firm in Geneva. As of 2015, he works in an international corporate and tax law firm in Zurich/Zug. He is a regular contributor to tax journals and lectures frequently in postgraduate tax programs. His main areas of expertise include Swiss, Liechtenstein and international tax law for individuals and corporations, incl. funds, trusts and foundations.

7 Chantal Raymond, David Carrie LLC, New York, graduated with a Juris Doctor from Harvard Law School after having completed a bachelor s degree in public relations at the University of Florida, which she attended using nine academic scholarships. At Harvard, her love for and commitment to her Caribbean roots moved her to become co-president and co-founder of the Harvard Caribbean Law Association. Chantal s life is marked by extensive voluntary contributions of her time and services. She also completed a political/ economic internship at the US Department of State, US Embassy, in Kingston, Jamaica. She also represented Jamaica at the Miss World 2010 competition held in Sanya, China. Manuel E. Tron, Manuel Tron S.C., Mexico City, graduated and made postgraduate studies in Economic and Corporate Law, and Tax Law at the Universidad Panamericana and attended the International Tax Institute (University of Wisconsin Law School). For more than 30 years, he has advised clients in both estate and succession planning (families, financial advisors and financial institutions) and corporate clients on international tax matters. He has been an advisor and instructor of international tax law matters for different areas of the Tax Administration Service in Mexico (SAT) and the Federal Tax Court. He has advised various ad hoc commissions of the Mexican Supreme Court, as well as the Tax Committees in both chambers of the Mexican legislature. He has advised and worked together with international organizations and foreign governments. He was the President of the International Fiscal Association (IFA) between 2009 and 2013 and was named Honorary President at the end of his second term. Dr Ernst J. Walch, Walch & Schurti Attorneys at Law, Liechtenstein, is senior partner of Walch & Schurti, one of Liechtenstein s foremost law practices (linked with a renowned trustee company providing services to international companies and high-wealth individuals). His firm has extensive litigation experience and is an acknowledged leading player in the commercial litigation field in Liechtenstein. He is admitted to practice law in both New York and Liechtenstein, where he has practiced since He also pursued a political career, being a member of the Liechtenstein parliament from 1989 to 1996, president of the parliament in 1993 and minister of foreign affairs from 2001 to He is a regular contributor to international journals, and lectures frequently at conferences. Dr René Vallaster, Allied Finance, Vaduz, has eight years of professional experience in the Liechtenstein trust business. He studied law at the University of Innsbruck before completing his training as a lawyer in Austria. He worked for a renowned Liechtenstein trust company for more than four years, before joining Allied Finance in Vaduz at the end of 2011, where he has since been working as Head of Fiduciary Services and as a client advisor. His area of expertise includes in particular the structuring of Liechtenstein legal entities and trusts in estate planning and asset protection.