MEXICO TAX UPDATE June 15 & 16, 2015 Manchester Grand Hyatt San Diego, CA

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1 A two-day intermediate level conference with live group instruction on the latest tax and legal strategies for reducing the cost of doing business in Mexico, featuring a discussion of Mexico-U.S. tax planning ideas for ::::::::::::::::::::::::::::::::::::: UPDATED FOR 2015! ::::::::::::::::::::::::::::::::::::: Overview of Topics to be Covered: Find out how the new labor reforms in Mexico affect employee profi t sharing plans Understanding the current rules for maquiladoras in Mexico What corporate tax practitioners need to know about FATCA issues in Mexico And more! All paid attendees will receive the Bloomberg BNA Portfolio: Doing Business in Mexico #972-4th (a $400 value) *One Portfolio per paid attendee. Quantities are limited. EARN UP TO 16 CPE/CLE CREDITS These unique courses are offered exclusively by Bloomberg BNA : : FACULTY: Steve Axler Special Counsel to Halliburton Houston, TX Michael Becka* Ernst & Young LLP Dallas, TX Jaime G. Bendiksen* BendiksenLaw Armando Beteta Ernst & Young LLP Dallas, TX Aaron Duarte Deloitte Alejandro Enriquez-Marsical BendiksenLaw, Cuidad Juarez David Escalante KPMG LLP Monterrey, CA Andres Fuentes Banamex-Citigroup Liliana Galindo KPMG LLP San Diego, CA Ricardo Gonzalez-Orta Deloitte Mexico Ricardo Rendon* Chevez, Ruiz, Zamarripa y Cia SC Simon Somohano Deloitte Mexico Bruce Stelzner KPMG LLP San Diego, CA Leobardo Tenorio-Malof TP Legal., S.C. Tenorio, Torres, Pedrin & Tortolero Zona Rio Tijuana *Chairpersons

2 MONDAY, JUNE 15, :00 AM Registration & Continental Breakfast 8:30 AM Overview of the Mexican Income Tax System Income recognition and deductions accrual basis, expenses, cost of sales, investments, NOL s carry forward Taxation of dividends (withholding tax and CUFIN rules) How the new labor reforms in Mexico affect employee profit sharing reviewing traditional service company structures and How income taxes and levies affect business operations using an independent or dependent agent to create PE status Choosing the proper vehicle for structuring operations in Mexico use of a holding company or joint venture 10:00 AM Break for Refreshments 10:15 AM SOX Corporate Governance Issues Affecting Operations in Mexico What corporate tax practitioners need to know about Sarbanes-Oxley (SOX) key FIN 48 issues in Mexico Common temporary and permanent differences for operations in Mexico impact of tax audits and litigation on disclosure of uncertain tax positions How to achieve auditor independence non-audit services prohibition Resolving conflicts between disclosure and attorney-client privilege Main effects of mandatory introduction of IFRs for companies listed in the Mexican stock exchange 11:15 AM Update on Manufacturing Alternatives and IMMEX/ MAQUILADORA Tax and Customs Benefits 12:15 PM Luncheon Key issues in structuring tax-efficient manufacturing operations in Mexico under the IMMEX Decree obtaining Certified Importer status and its benefits Update on modifications to qualify for a MAQUILADORA regime for Income tax and its PE protection rules Update on MAQUILADORA transfer pricing guidelines- applying for an APA Impact due to the revocation of the Presidential Decree for maquiladora companies Benefits and requirements under the New Empresa Certificada Program ( NEEC ) 1:15 PM Financing Operations in Mexico Use of debt vs. equity in financing operations review of the thin capitalization rules in Mexico Book and tax differences in accounting for inflation Obtaining benefits for interest deductions in Mexico Withholding tax impact on interest payments Treatment of exchange gains/losses How to use cross-border leasing for transferring equipment to Mexico dealing with withholding tax issues Using both debt and equity financial derivative transactions Futures, options, hedges and swaps Understanding the new REIT and venture capital tax systems in Mexico 2:45 PM Break for Refreshments 3:00 PM Mexico M&A Legal and Tax Update Structuring taxable v. tax-free mergers in Mexico how recent tax law changes affect acquisition and merger activity How to achieve de-mergers and spin-offs tax free while preserving tax basis and other attributes Stock v. asset acquisitions in Mexico obtaining a basis step-up in Mexico Transfers and amortization of intangibles from the buyer s and seller s perspective - dealing with goodwill issues Conducting legal and tax due diligence in reviewing purchase or merger agreements - dealing with joint liabilities and escrow accounts

3 4:15 PM Royalties, Technical Assistance and Intragroup Services Tax issues involving cross-border royalty and technology transfers U.S.-Mexico income tax treaty planning Tax treatment of payments for the use of software in Mexico BEPS Impact on intercompany charges Issues in implementing Cost Contribution Agreements with Mexican subsidiaries Use of intercompany services and management fees advantages and disadvantages of using a conduit entity Understanding the domestic legislation of non-deduction on pro-rata allocations with non-residents 5:15 PM Conference Adjourns for the Day TUESDAY, JUNE 16, :30 AM Continental Breakfast 8:00 AM Mexico Taxation of Oil and Gas Tax Implications in connection to the government take specifically regarding profit production sharing and/or license agreements Tax treatment of signing bonus, exploration quotas and license payments Special depreciation rates for investments in the oil and gas industry Employee profit sharing exemption rules for oil and gas companies Permanent Establishment rules for non-residents regarding oil and gas activities and taxation rules for non-resident individuals performing services in Mexico 8:45 AM Dispositions and Reorganizations Involving Subsidiaries in Mexico Elections on private shares and new rules for the taxation of publicly traded shares - Computing adjusted basis of the stock and paying the tax on net basis Strategies for liquidating or disposing of subsidiaries in Mexico Taxation of contribution and transfer of appreciated property migration and deemed liquidation rules Advantages and disadvantages of the tax integration regime Comparison of U.S. and Mexico rules for taxable v. tax-free reorganizations how to apply for a tax deferral ruling Main tax implications in reorganizations through mergers and de- mergers Using stock redemptions and capital reductions to restructure operations in Mexico Avoiding black list and the Mexico CFC rules on sale or reorganization transactions 9:45 AM Break for Refreshments 10:00 AM Key Tax Issues in Sending Individuals to Mexico How Mexico taxes activities of non-resident individuals When a non-resident working in Mexico on temporary assignment is subject to income or withholding tax Stock options compensation-mexican tax treatment Dealing with payroll and other social taxes. How Mexico taxes income earned by resident alien individuals living in Mexico avoiding black list and Mexico CFC rules 11:25 AM Mexico VAT (Value-Added Tax) and Excise Taxes Update Dealing with Value Added Tax (VAT) issues understanding how the cash basis and credit system operates in Mexico Documentation of eligible credits procedural aspects How to recover VAT credits and refundable amounts Understanding the 0% VAT rate for exportations of services Understanding New Excise taxes on food and soft drinks

4 12:30 PM Luncheon 1:15 PM U.S. Mexico Transfer Pricing Issues Understanding the transfer pricing and penalty guidelines in Mexico use of secret comparables How to deal with the Mexican reporting requirements for Transfer Pricing Information Returns Impact of US services regs related to Mexico operations Increasing audit scrutiny of inter-company transactions issues in deductibility of cost allocations Update on SAT specialized tax transfer pricing audits. Approaching business restructuring regarding commissioners and supply chain Filing for a bilateral APA and other Competent Authority proceedings 2:30 PM Break for Refreshments 2:45 PM Resolving Tax Controversies in Mexico Understanding the Mexican tax legal system/procedures Tax assessments and appeals Practical approach to settlements New settlements procedure before the tax Ombudsman (Prodecon) Jurisprudence and Amparo proceedings Recent Mexican court cases and trends on international tax disputes Update of IRS tax and customs audit approach regarding U.S. companies doing business in Mexico 4:00 PM Conference Concludes Times/topics/speakers subject to change 2015 The Bureau of National Affairs, Inc. All rights reserved. WHY YOU SHOULD ATTEND The 2014 Mexico Tax Reform and subsequent changes have resulted in important changes to the Mexican tax landscape with regards to income tax and VAT treatment. Also, recent changes in the Mexican labor rules may require U.S. companies to re-examine their employee profit-sharing plans in Mexico. New topics have been added on Mexican Oil & Gas Reform, Mexican REITs and treatment of profits on venture capital and hedge funds in Mexico. WHO SHOULD ATTEND This conference is intended for corporate tax directors, managers, controllers and attorneys, as well as practicing CPAs and lawyers with clients doing business in Mexico and other financial executives responsible for business operations in Mexico. No prerequisites/ advanced preparation necessary. This program is transitional and nontransitional which is appropriate for both newly admitted attorneys and experienced attorneys. CONFERENCE LOCATION Manchester Grand Hyatt One Market Place, San Diego, CA Tel.: A limited number of rooms are available at the reduced rate of $279 per night. Contact the Manchester Grand Hyatt and ask for the Bloomberg BNA room block to book. Our block of discounted sleeping rooms is limited, so please reserve your sleeping room early! We cannot guarantee rates or availability. Please contact the hotel and mention that you are attending the course listed under Bloomberg BNA. This limited-time discounted rate will be available up to 30 days prior to the meeting, or until the group block is sold-out, whichever comes first. Please note: your sleeping room is not included in the registration fee. REGISTER EARLY & SAVE $100!

5 FIVE EASY WAYS TO REGISTER: WEB: TELEPHONE: FACSIMILE: MAIL: Bloomberg BNA s Customer Contact Center 3 Bethesda Metro Center, Suite 250 Bethesda, MD USA HARDSHIP POLICY Bloomberg BNA offers a hardship policy for CPAs and other tax and accounting professionals who wish to attend our live conference and seminars. Individuals must earn less than $50,000 annually in order to qualify. For individuals who are unemployed or earning less than $35,000 per year, a full discount off the price of registration for the program will be awarded. Individuals earning between $35,000 and $50,000 per year will receive a 50% discount off the price of the program. If an individual wishes to submit a case for hardship, he or she must contact Bloomberg BNA directly at accreditations@bna.com. Please include the following information with your request: complete contact information, program for which a hardship reduction is being requested, requested amount for hardship reduction, and reason for applying for hardship. Please note that requests will not be considered until 30 days from the program date and that individuals may only apply for a hardship reduction once within a 12-month period. Bloomberg BNA reserves the right to make a final determination on a case-by-case basis. Our decision for granting a hardship is final and submission does not constitute acceptance. FEE INCLUDES Continental breakfasts, lunches, refreshment breaks, Bloomberg BNA Portfolio and course materials in electronic format. Contact Bloomberg BNA about discounts for three or more registrants from the same company. SPONSORSHIP OPPORTUNITIES ARE AVAILABLE Contact Bloomberg BNA at customercare@bna.com or call CANCELLATION POLICY If you are unable to attend this event, you may: transfer your registration to another person from your company for the same event; or transfer your registration to a substitute event listed on our web site. In either instance, there will be no charge or penalty for substitution. To request a transfer, contact customercare@bna.com with the new attendee or substitute event information more than 5 business days prior to the conference start date. On the first day of the event, absent attendees will be considered no shows and will not be eligible for a refund, transfer, or substitute event. Cancellations must be made in writing to customercare@bna.com more than 5 business days before the event and will be assessed a $350 conference setup fee. Cancellations will not be accepted if notice is received fewer than 5 business days before the event. For more information regarding administrative policies, complaints and cancellations, please contact us at , or customercare@bna.com. EARN UP TO 16 CPE/CLE CREDITS Bloomberg BNA is registered with the National Association of the State Boards of Accountancy 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. Complaints regarding registered sponsors may be addressed to NASBA, 150 Fourth Avenue North, Suite 700, Nashville, TN Bloomberg BNA will apply for continuing legal education credits in any state or jurisdiction where available. For more information, please contact Bloomberg BNA customer service at and ask to speak to the CLE Accreditations Coordinator, or us at accreditations@bna.com. :::::::::::::::::::::::::::::::::::::::::::::::::::: REGISTER EARLY & SAVE $100! Mexico Tax Update TMC262 $1, Early Registration (up to 1 month prior to course) $1, Registration (within 1 month of course) Name Title Organization Method of Payment: Payment is due on or prior to the course. All credit cards converted to and billed in U.S. dollars (USD). Check enclosed payable to Bloomberg BNA Credit card payment: MasterCard Visa AmEx Discover All credit cards will be processed at current U.S. conversion rates Address City State Zip Card No. Telephone Fax V-code /Billing Zip Card Expiration Date Signature

6 Bloomberg BNA s Customer Contact Center 3 Bethesda Metro Center, Suite 250 Bethesda, MD MEXICO TAX UPDATE >>>>> A two-day intermediate level conference with live group instruction on the latest tax and legal strategies for reducing the cost of doing business in Mexico, featuring a discussion of Mexico-U.S. tax planning ideas for :::::::::::::::::::::::::::::::::::::::::::::::::::::::: ::::::::::::::::::::::::::::::::::::::::::::::::::::::::