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| IBSA News |
Hot off the press: The Principles of International Tax Planning by Roy Saunders and IFS Consultants.
The book has undergone significant restructuring and development since it was first published in 2005. The principles are brought to life through a case study of a fictitious family with an abundance of personal and corporate tax issues.
The book is aimed at multi-disciplinary practitioners, such as accountants, bankers, lawyers, tax advisers, IP specialists, corporate finance advisers and managers of trust companies, as well as students who will benefit from studying The PITP, either in depth or as a useful reference book.The book is free to IBSA members – who will receive their copy shortly by post – and £95 to non-members.
Launch after launch – strength to strength
1 October: Hosted by the Malta Institute of Management, the launch of the IBSA in Malta included a seminar on a multi-disciplinary approach to international business structuring compliant with international transparency, corporate governance and social responsibility.
8 October: The launch of the North American Branch took place at Thomson Reuters’ Times Square offices in New York. Leading industry experts discussed issues such as US CFC legislation, holding companies, corporate re-domiciliation, inversions and the impact of the OECDs BEPS initiative on transfer pricing. |
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UK Branch Meeting - 16 September
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Knowledge Bank article – Fiduciary Relationships in International Business Structuring
This was the fourth event in the UK Branch programme of activities. Whilst fiduciary relationships were the focus of the evening, the panel also discussed issues relating to the exchanges of information that are available to government authorities in different jurisdictions, in particular, how exchange of information regimes are developing in response to the Foreign Account Tax Compliance Act (FATCA) initiative introduced by the US, and how disclosure, or indeed nondisclosure of information, can determine the outcome of family law cases.
The concept of beneficial ownership was also addressed as a common and related misconception on the part of clients: that a trust or corporate entity, established for the purposes of exploiting a particular tax treaty or ring-fencing personal assets, will withstand the scrutiny of a tax administration or family law court.
Read the full summary of the 16 September UK Branch discussion group on the IBSA Knowledge Bank.
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New York Panel Discussion - 8 October
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In addition to launching the IBSA in North America, our recent event in New York played host to a panel discussion on US corporate inversions. Bernhard Gilbey of Squire Patton Boggs, Robert Kiggins of Culhane Meadows and Saumyanil Deb of Thomson Reuters discussed the key issues under scrutiny in the US at present.
Robert Kiggins opened the discussion by referring to the disparity of US corporate tax rates with the rest of the world. With the nominal federal corporate tax rate of 35% plus state taxes, and, for those operating in New York City, city taxes as well, the overall corporate tax rate can easily rise to the mid-forties. This can be compared to the forthcoming 20% corporate tax rate in the UK and 12.5% in Ireland. Add to that the fact that the US does not have a territorial tax system, and it is therefore no wonder that US corporations are looking to reduce their corporate tax bills.
Read the full summary on the IBSA Knowledge Bank.
EU Commission: State aid investigations
Keith Brockman, Mars Ltd
Keith provides some key observations on the European Commission’s formal state aid investigations into tax rulings granted by Ireland (Apple) and Luxembourg (Fiat).
Alternative Investment Fund Managers Directive
Wendy Piergolam, Orangefield
Orangefield provides guidance on the Alternative Investment Fund Managers Directive and its implications for both European and non-European fund managers.
States of Guernsey Budget Report for 2015
André Trebert, BDO Limited
André outlines proposed changes to the Guernsey tax regime following the recent Budget for 2015.
Client note: Mediation?
Bree Taylor and Victoria Prince, Memery Crystal
Memery Crystal provides guidance on the circumstances in which clients should mediate before they litigate.
Tax reform in Spain
Alix Sáenz de Cenzano Fargues, Cristina Ferrer-Sama, Jaime Azcona, Azcona Asociados
This article provides a summary of the main fiscal changes that are expected to enter into force from 1 January 2015.
Corporate residence
Roy Saunders, IFS Consultants
Roy considers the concept of management and control, the implications of corporate residence and how to ensure that a company is non-resident in a particular country.
Taxation of estates in the United States
Felicia M. Seaton, Felicia Seaton Law
Felicia provides an overview of US estate taxes and how they apply to citizen decedents and non-citizen decedents. |
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| Upcoming Events |
With directors from large multinationals and partners from top 100 law firms speaking on topics including tax inversions, IP valuation and acquisition financing in emerging markets, the Mandarin Oriental, London conference provides a great opportunity to meet thought leaders on trends in cross-border corporate acquisitions and to generate new business contacts.
A cocktail reception will follow the event, which you still have time to register for taking advantage of your 20% member’s discount.
Hong Kong – 21 November
Join Sanjay Iyer for an Introduction to International Tax Planning, kindly sponsored by the Ivey Business School at Western University.
This is a practical, ‘how-to’ course aimed at practitioners, CFOs and treasurers who wish to learn more about the principles of international tax planning.
London - Branch Meeting - 2 December
The next UK Branch meeting takes place in early December and will cover Corporate Finance & the AIM Markets. The AIM market is one of the world's most successful growth markets helping to fund acquisitions and to attract and motivate management to smaller companies.
2015 event details are currently being finalised. Make sure you keep up to date with all Branch activity by visiting the Events pages. Please note that IBSA members are entitled to attend Branch meetings anywhere in the world and receive a discount on all conferences.
Save the date! Details to be confirmed.
• India – 12 January 2015, Mumbai
• Switzerland – 22 January 2015, Geneva
Make sure you keep up to date with all Branch activity by visiting the relevant Branch pages and of course, we will keep in touch with events coming near you!
Visit www.istructuring.com to see what’s new! Reminder: to get the most out of our Corporate and Services directories, please ensure that all your profile information – both individual and corporate – is up to date. Contact jay.abai@istructuring.com to provide updated information.
The IBSA produces a series of live and on-demand webinars for its members via our Bright Talk Channel.
On 18 September, John Timpany and Roy Saunders presented a 45 minute webinar comparing the limitation of benefit provisions of various double tax treaties. Matters discussed included identification of treaties that contain remittance and limitation of benefit clauses, permanent establishment exemptions and how an absence of participation exemptions in the US is driving the trend for corporate inversions.
Register with Bright Talk to listen to a recording of this webinar, to download slides and for details of upcoming webinars that include a discussion of FATCA & Exchange of Information Issueson 20 January 2015.
Event Gallery
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| Roy Saunders, Founder of the IBSA, introduces the panel at the 16 September UK Branch discussion group.
Discussion group attendees network with speaker Peter Grant, Director of Operational Taxes at KPMG.
Attendees at the Malta launch on 1 October.
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