Chairs

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.

Andrés Sánchez

Cuatrecasas, Madrid

Mr. Sánchez began his career in the tax practice of Arthur Andersen Asesores Legales y Tributarios before joining Cuatrecasas in 1998.

Throughout his career, Andrés Sánchez has specialized in advising on tax issues relating to crossborder transactions in the following four areas: foreign investment in Spain, Spanish investment abroad, the restructuring of multinational groups, and projects and infrastructure.

Regarding foreign investment in Spain, he has experience in private and public M&A, and in advising foreign groups on setting up in Spain. He has also advised Spanish groups on both carrying out M&A transactions and setting up abroad. Mr. Sánchez has advised on restructuring Argentinean, Brazilian, Colombian and Mexican groups into Spanish holding companies, as well as advising European, US and Asian groups on investing in Latin America.

Keynote Speakers

Manuel Tron

Manuel Tron, Mexico City

Manuel is a specialized tax attorney with vast experience in international tax law. For over thirty years, Manuel has been providing legal consulting and planning services to international businesses from a tax perspective, as well as personal and family counseling related to wealth and estate planning both in Mexico and abroad. His practice primarily involves the design of structures for cross-border investment both from abroad to Mexico, and from Mexico internationally. Manuel is regularly involved in designing strategies for negotiation and resolution of tax disputes both in Mexico and abroad and assisting in tax litigation matters on a federal level.

He is an Honorary President of the International Fiscal Association after being President of the Association, and is recognized on the international legal scene as one of Mexico's most renowned tax lawyers.

Manuel has taught extensively on subjects related to tax law at various universities in Mexico and abroad, has lectured on international tax issues and authored numerous articles in publications specialized in tax matters. Manuel is fluent in English, Spanish and French.

Peter Blessing

Associate Chief Counsel (International), Internal Revenue Service (IRS), Washington, DC

Mr. Blessing is the Associate Chief Counsel (International) in the office of Chief Counsel, Internal Revenue Service.  He oversees an office of approximately 95 attorneys and other professionals responsible for legal advice, guidance, and support to the IRS, Treasury, and the public on international tax issues in all procedural postures. 

Prior to joining the IRS Chief Counsel’s office, Mr. Blessing practiced as a member of the International Tax unit and the Complex Transactions unit within the Washington National Tax practice at KPMG LLP.  He was a partner for over 25 years with Shearman & Sterling LLP, where his practice focused on international tax matters and financial institutions. Mr. Blessing received his B.A. from Princeton University.  He received his J.D. from Columbia Law School and his LL.M (Taxation) from New York University School of Law.

Speakers

Alberto Benshimol

D'Empaire, Caracas

Alejandro Santoyo

Creel, García-Cuéllar, Aiza and Enriquez, Mexico City

Alex Córdova

Rodrigo, Elías & Medrano, Lima

Alvin Shrago

Deputy Head of Group Tax Americas, UBS, Connecticut

Ana Claudia Akie Utumi

Utumi Lawyers, São Paulo

Devon Bodoh

Weil, Gotshal & Manges, Washington, DC

Eduardo Cukier

Curtis, Mallet-Prevost, Colt & Mosle, New York

Emiliano Baidenbaum

Senior Counsel, Hewlett Packard, New York

Enrique Hernández-Pulido

Procopio, Cory, Hargreaves & Savitch, San Diego

Fernando Camarena Cardona

Foley Gardere Arena, Mexico City

Fernando Tonanni

Machado Meyer, São Paulo

Fernando Zuzunaga

Zuzunaga, Assereto & Zegarra, Lima

Gabriela Pellón Martínez

Galicia, Mexico City

Igor Nascimento da Souza

Madrona, São Paulo

Jessica Power

Carey, Santiago

Jorge San Martín Elizondo

SMPS Legal, Mexico City

Jose Chiarella

Damma Legal Advisors, Lima

Juan Camilo de Bedout

Posse Herrera Ruiz, Bogotá

Mauro Mascareño

BKM | Berkemeyer, Asunción

Programme

9.00: Welcome coffee and registration

9.30: Chairs’ morning welcome

Andrés Sánchez, Cuatrecasas, Madrid
Celso Costa, Machado Meyer, São Paulo

9.40: Morning keynote – Outbound perspectives

10.10: Inbound perspectives in the post US Tax Reform era – two years down the road

This panel will discuss the consequences of the 2017 US tax reform and its effect on investments in Latin America. How has the reform, which encouraged companies to bring their profits back to the US, impacted US and multinational companies’ investment behaviours? The discussion will bring Latin American perspectives and cover everything from acquisition structures and exit strategies to foreign tax credit and treasury management to anti-deferral regimes.

Moderator:
Enrique Hernández-Pulido, Procopio, Cory, Hargreaves & Savitch, San Diego

Panel:
Jorge San Martín Elizondo, SMPS Legal, Mexico City
Eduardo Cukier, Curtis, Mallet-Prevost, Colt & Mosle LLP, New York
Peter Blessing, Associate Chief Counsel (International), IRS, Washington, DC
Alvin Shrago, Deputy Head of Group Tax Americas, UBSConnecticut

11.20: Coffee Break

11.40: Digital economy: Taxation of cryptocurrency and digital presence

This extended panel will include two separate topics related to the digital economy. First up is the role of bitcoin and other forms of cryptocurrency,  and the growing number of players involved (investors, brokers, exchange and services companies). Specific tax regulations linked with the phenomenon are few, leaving interested parties with a lot of uncertainty. This panel will address existing regulations in several jurisdictions in the region and their consequences on cross-border acquisitions, cryptocurrencies sales and coin valuations.

The panel will then turn to where the corporate taxation of companies active in digital economy should take place. How do Latin American jurisdictions address transactions in the digital economy in relation to non-resident entities that are doing business, raising capital or investing from specific countries’ borders. What are the strategies to attract local taxation on such businesses? Which taxes are imposed? Are jurisdictions prepared to handle with the challenges of the swiftly evolving digital economy?

Moderator:
Ana Claudia Akie Utumi, Utumi, São Paulo

Panel:
Fernando Camarena Cardona, Foley Gardere Arena, Mexico City
Jose Chiarella, Damma Legal Advisors, Lima
Emiliano Baidenbaum, Senior Counsel, Hewlett Packard, New York

12.55: Networking Lunch

14.10: Afternoon keynote – Trends in Latin American tax reforms

Manuel Tron, Founder of Manuel Tron, Mexico City

14.40: Funding operations in Latin America: International cash pooling

With multinational companies doing business through multiple subsidiaries across Latin America in different currencies, cash pools are a necessary and useful financial tool for companies. Their importance has only grown as financial and market instability bites. This panel will analyse current tax regulations’ impact on cross-border financing structures and cash pooling arrangements in the region. The discussion will take into consideration rules about intragroup financing, interest deductibility, withholding and VAT taxation. Panellists from several jurisdictions will provide a comparative analysis to demonstrate how different Latin American countries regulate these transactions and identify the best jurisdictions to settle treasury activities.

Moderator:
Andrés Sánchez, Cuatrecasas, Madrid

Panel:
Jessica Power, Carey, Santiago
Alberto Benshimol, D'EmpaireCaracas
Gabriela Pellón Martínez, Galicia, Mexico City
Igor Nascimento de Souza, Madrona Advogados, São Paulo 

15.40: Coffee break 

15.55: Disclosure of uncertain tax positions

Tax planning is the target of IFRS, BEPS and tax authorities’ actions across the region. This panel will focus on the current and potential future obligations imposed on taxpayers to disclose their uncertain tax position. What is the status of IFRIC 23 (uncertainty over income tax treatments) in the region? Panellists will also discuss the legality of these disclosures in different local legal and regulatory frameworks. It will also cover the role of lawyers and how they handle matters and advise clients in this context.

Moderator:
Alejandro Santoyo, Creel, García-Cuéllar, Aiza y Enriquez, Mexico City

Panel:
Juan Camilo de Bedout, Posse Herrera Ruiz, Bogotá
Fernando Tonanni, Machado Meyer, São Paulo
Fernando Zuzunaga, Zuzunaga, Assereto & Zegarra, Lima

16.55: M&A transactions: Indirect transfer of assets

Another year has past since US’ largest tax reform in decades was passed. Together with the  BEPS actions and amendments to local tax codes, these regulations play important roles in Latin America’s globalised markets. How are these changes impacting interantional and cross-border M&A transactions? This panel will focus on the indirect transfer of assets held by multinational companies. What are the tax consequences for companies in these transctions? How does local capital gains taxation in different jurisdictions affect transactional strategies? How should local advisors guide their clients? The discussion will include perpsectivs from different countries and include issues about price allocation, anti-evasion rules and the need for local contracts.

Moderator:
Celso Costa, Machado Meyer, São Paulo

Panel:
Alex Córdova, Rodrigo, Elías & Medrano, Lima 
Devon Bodoh, Weil, Gotshal & Manges, Washington, DC
Mauro Mascareño, BKM | Berkemeyer, Asunción


17.55: Chairs’ closing remarks

Andrés Sánchez, Cuatrecasas, Madrid
Celso Costa, Machado Meyer, São Paulo

Venue

Omni Berkshire Place, 21 East 52nd Street at, Madison Ave, New York, NY 10022, United States

Ticket Prices

Private Practitioner
Type Price Expires
Super Early $550  25 Oct 2019
Early $750 22 Nov 2019
Standard $950 02 Dec 2019

 

In-house/governmental
Type Price
Standard
Complimentary