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2019 May Meeting

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(c) [2019] American Bar Association.
All rights reserved. No part of this recorded content may be reproduced, stored in a retrieval system, or transmitted, in any form or by any means, electronic, mechanical, photocopy, recording, or otherwise, without the prior written permission of the American Bar Association.

$299.00



Showing sessions 41 - 42 of (42) TOTAL sessions
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Event : ABATX42


Session : ABATX1988
Foreign Lawyers Forum
Conference : 2019 May Meeting
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$45.00


  • Chair: Laura Gould, Reed Smith LLP, London, United Kingdom
  • What’s My Purpose: The Practical Implications of the Principal Purpose Test. Join us for an interactive session on the application of the principal purpose test (PPT) and how it applies to non-US tax treaties, which have been updated following the implementation of the OECD multilateral instrument. This panel will discuss the PPT and explore how a cross-section of different tax authorities are likely to interpret its provisions, drawing on existing OECD guidance, case law and other anti-abuse rules and GAARs. Expect some audience participation as the panel looks at case studies and considers whether certain scenarios would pass or fail the PPT. The panel will also explore how the PPT could change how multinationals, investment funds and financial institutions structure their cross-border activities and what that might look like in practice from a tax and business perspective. The multi-jurisdictional panel of experts will also provide updates on other recent key international tax developments. Moderator: Amanda P. Varma, Steptoe & Johnson LLP, Washington, DC. Panelists: Dèlcia Capocasale, Cuatrecasas, New York, NY; Kathleen Penny, Blake Cassels & Graydon LLP, Toronto, ON; Elena Rowlands, Travers Smith LLP, London, UK; Romain Tiffon, Atoz, Luxembourg; Philip Tully, Matheson, Dublin, Ireland


Session : ABATX1989
Section Program - Welcome to International Private Client: Fundamentals of Cross-border Estate Planning, Estate and Gift Tax Treaties, and Foreign Trusts
Conference : 2019 May Meeting
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  • Co-Sponsored by: Continuing Legal Education Committee (“CLE”); U.S. Activities of Foreigners and Tax Treaties ("USAFTT"); Foreign Activities of U.S. Taxpayers (“FAUST”).IRS and private practitioners will present a three-part workshop that will focus on the fundamentals of international private client. This workshop is intended to be an introduction to the international private client practice for junior attorneys and a refresher for more seasoned practitioners. The workshop will be divided into three panels: Cross-border Estate Planning, Analyzing Foreign Trusts, and Interpreting Estate and Gift Tax Treaties.
  • Cross-Border Estate Planning. This panel will focus on provisions of the US tax code relevant to assessing and implementing cross-border estate planning. Points of discussion will include identifying the tax status of the taxpayer and the taxpayer’s family (i.e. citizenship, tax residency, domicile), the type and situs of the taxpayer’s worldwide assets (i.e. tangible or intangible and U.S. or foreign), the impact of income and estate tax treaties (also see the third session below “Interpreting Estate and Gift Tax Treaties” for a more thorough analysis), and common planning pitfalls and considerations (i.e. blocker entities, trusts, FIRPTA, outbound transfers, inversions, PFICs, and CFCs). Moderator: Daniel J. Bell, McDermott Will & Emery, Washington, DC. Panelists: Alison F. Egan, Caplin & Drysdale, Washington, DC; Severiano E. Ortiz, RSM US LLP, Washington, DC; Additional Panelist TBA
  • Analyzing Foreign Trusts. This panel will focus on the application of the US tax laws as they relate to identifying foreign versus domestic trust structures. This panel will outline a roadmap from which to analyze trust deeds and discuss some of the key nuances in the grantor trust rules that cause the practitioner to reexamine the trust based on direct/indirect transfers to the trust or on changes in the income tax residency of the trust parties. Moderator: Alexander M. Lewis, RSM US LLP, Washington, DC. Panelists: Dianne C. Mehany, Caplin & Drysdale, Washington, DC; Severiano Ortiz, RSM US LLP, Washington, DC; Richard LeVine, Withers Bergman LLP, New Haven, CT; Additional Panelist TBA
  • Interpreting Estate and Gift Tax Treaties. This panel will focus on the provisions relevant to the application of the US gift and estate tax; including residence/domicile, sourcing, situs, and exemptions. This panel will address fundamentals of US tax treaty policy (past and present) and explain how the substantive rules provided in US tax treaties may produce results that differ from those described in the other two panels. Estate and gift tax treaties contain numerous rules regarding the allocation of taxing rights with respect to qualifying individuals and their interests in property that can vary substantially from the US statutory scheme. These rules serve to minimize double taxation in the areas of lifetime gifts and transfers at death. In addition, the panel will draw attention to certain overriding rules of interpretation contained within treaties that can trip up the unsuspecting practitioner. Moderator: Professor Patricia A. Brown, University of Miami, Miami, FL. Panelists: Leslie A. Share, Packman Neuwahl & Rosenberg, Miami, FL; Scott Snyder, Packman Neuwahl & Rosenberg, Miami, FL; Additional Panelist TBA



     


Showing sessions 41 - 42 of (42) TOTAL sessions
(PREV 10)  1 2 3 4 5


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