Thursday, 8 November 2018, The Betsy South Beach, 1440 Ocean Drive, Miami Beach, Florida 33139, USA

E-mail Tel: +44 20 7908 9222

Chairs

Michael Silva

DLA Piper, Miami

Michael Silva focuses his practice on international tax law, with emphases on US investment structures, cross-border tax issues, tax treaty planning, withholding obligations of US real property investments and US activities of foreign banks. He has significant experience providing counsel in connection with the Foreign Account Tax Compliance Act (FATCA), a complex, unilateral US tax legislation that imposes third-party reporting obligations on global financial entities.

Celso Costa

Machado Meyer, São Paulo

Celso has extensive experience in M&A, reorganizations, cross-border transactions, transfer pricing and general advisory. Solid background in corporate law. Accounting skills acquired in a leading accounting firm. In depth knowledge of administrative litigation. Continuously involved in several of the largest M&As, reorganizations and IPO's. His practice includes advisory on financial and insurance services, infrastructure, information technology, manufacturing and mining advisory.

Keynote Speaker

Yariv Brauner

Professor, University of Florida Levin College of Law, Gainesville

Yariv Brauner joined the Florida faculty in 2006, after teaching at NYU, Northwestern and ASU. He has been a Visiting Professor or a guest speaker in various universities in the U.S. and abroad. He is an author of articles published in professional journals and law reviews, and a co-author of U.S. International Taxation – Cases and Materials (with Reuven S. Avi-Yonah and Diane M. Ring), now in its 3rd. ed.

Speakers

Adrián Rodríguez

Lewin & Wills, Bogotá

Alberto Benshimol

D'Empaire, Caracas

Alex Fischer

Baraona Fischer Spiess, Santiago

Antonio Macias Valdes

DLA Piper, Miami

Cynthia Munailla Carbajal

Afisca, Lima

Devon Bodoh

KPMG, Washington DC

Fernando Camarena

Foley Gardere Arena, Mexico City

Fernando Tonanni

Machado Meyer, São Paulo

Gabriela Pellón

Galicia, Mexico City

João Magalhães Ramalho

PLMJ, Lisbon

Jorge San Martin

SMPS, Mexico City

Jose Madariaga

Senior Tax Manager, LATAM, Santiago

Julián Vásquez

Regional Head of Legal and Compliance, USA, Compass Group, New York

Luis Rodrigo Salinas Olvera

Director General of International Tax Affairs, Taxpayers' Ombudsman, Mexico City

Manuel José Alcalde Peñafiel

Head of Tax Policy, Ministry of Finance, Santiago

Mauro Mascareño

Berkemeyer, Asunción

Rafael Luna Rodríguez

Consortium Legal, San José

Richard Winston

Winston Legal Group, Miami

Robert Jefferson

International Tax Manager, Crowley Maritime, Jacksonville

Scott Campbell

Global Tax Director, AT-PAC, Roswell

Suchi Lee

PwC, New York

Wilson Vieira

Senior Manager, Global Tax, Sitel, Miami

9.00: Welcome coffee and registration

9.30: Chairs' morning welcome

Celso Costa, Machado Meyer, São Paulo
Michael Silva, DLA PiperMiami

9.40: Keynote address

Yariv Brauner, Professor, University of Florida Levin College of Law, Gainesville

10.10: Taxing the digital economy

Companies active in the world's vast digital economy create new challenges for tax authorities, which must contend with limited regulation and understand entirely new business models. This panel will analyse the different strategies Latin America countries use to tax the download of software, apps, streams, software as services, online adverts, webhostings and cloud computing offerings. Will withholding taxes and/or VAT taxes imposed at the source of income remain the norm, or is change afoot? The potential issues concerning VAT double taxation, which is usually not covered by tax treaties, will also be discussed as speakers shed some light on what is often a grey area of tax law.

Moderator:
Celso Costa, Machado Meyer, São Paulo
 
Panel:
Alberto Benshimol, D'Empaire, Caracas
Alex Fischer, Baraona Fischer Speiss, Santiago
Gabriela Pellón, Galicia, Mexico City
Rafael Luna Rodríguez, Consortium Legal, San José

11.10: Coffee break

11.30: Transfer pricing and customs duties

This new transfer pricing era means multinational enterprises must have a comprehensive and proactive approach to transfer pricing matters to minimise exposure to significant risk. In particular, transfer pricing issues related to customs duties and other indirect taxes have emerged as stumbling blocks. This is because any price changes after the value is declared at customs can lead to negative adjustments from a customs perspective. Moreover, some Latin America tax authorities may view year-end adjustments as non-deductible. This panel will provide insight from clients as well as Latin America practitioners concerning best practice when dealing with transfer pricing related to customs and other indirect taxes.

Moderator:
Antonio Macias Valdes, DLA Piper, Miami
 
Panel:
Jose Madariaga, Senior Tax Manager, LATAM, Santiago
Julián Vásquez, Regional Head of Legal and Compliance, USA, Compass Group Holdings, New York
Robert Jefferson, International Tax Manager, Crowley Maritime, Jacksonville
Scott Campbell, Global Tax Director, AT-PAC, Roswell

12.30: Networking lunch

13.45: The 2017 US tax reform and its effect on US-Latin American investment

The US is the largest source of foreign direct investment in Latin America, but the passage of major tax reforms late last year may profoundly change this relationship. Prior to the reforms, US companies often paid taxes on the income they earned abroad by using credit for taxes paid by their subsidiaries. Because US companies only paid taxes when money was remitted to the US, this created an incentive to keep profits abroad. With the new US tax code encouraging companies to bring their profits home, what impact will this have on US subsidiaries located in Latin America? Are profits now being shifted to the US? Will lower corporate tax rates and other policies discouraging offshore dealings result in US companies reducing Latin American investment? Panelists will thoroughly investigate the subject and bring clarity to the debate.

Moderator:
Richard Winston, Winston Legal Group, Miami
 
Panel:
Mauro Mascareño, Berkemeyer, Asunción
Suchi Lee, PwC, New York
Wilson Vieira, Senior Manager of Global Tax, Sitel, Miami

14.45: Coffee break

15.10: An update on OECD-inspired tax reforms

Many Latin American countries have fought hard to become members of the OECD over the past five years, but the organisation's recent clamp down on tax evasion has demanded considerable tax reform. This panel will ensure delegates get the latest news on the implementation of BEPS actions in Latin America and hear what remains to be done. Panellists will also elaborate on the challenges associated with implementing OECD-inspired directives in their legal practice.

Moderator:
João Magalhães Ramalho, PLMJ, Lisbon

Panel:
Adrián Rodríguez, Lewin & Wills, Bogotá
Cynthia Munailla Carbajal, Afisca, Lima
Luis Rodrigo Salinas Olvera, Director General of International Tax Affairs, Taxpayers' Ombudsman, Mexico City
Manuel José Alcalde Peñafiel, Head of Tax Policy, Ministry of Finance, Santiago

16.10: The impact of US and global tax reforms on M&A transactions

The biggest US tax reform in three decades along with the major changes caused by BEPS and the EU are fundamentally changing the global tax space. What impact is this having on Latin American transactional planning and how can lawyers best respond? This panel will analyse the effect of these changes on the traditional M&A structures used by Latin America investors to invest in the US and vice versa.

Moderator:
Devon Bodoh, KPMG, Washington, DC

Panel:
Fernando Tonanni, Machado Meyer, São Paulo
Jorge San Martin, SMPS, Mexico City
Michael Silva, DLA Piper, Miami

17.10: Chairs' closing remarks 

Celso Costa, Machado Meyer, São Paulo
Michael Silva, DLA PiperMiami

17.20 onwards: All delegates are invited to attend a drinks reception kindly hosted by KPMG

Venue

The Betsy South Beach, 1440 Ocean Drive, Miami Beach, Florida 33139, USA

Private Practitioner
Type Price Until
Super Early $550 21 September 2018
Early $750 26 October 2018
Standard $950 8 November 2018

 

In-house/Governmental
Complimentary In-house/Governmental registration available