7th annual iba finance & capital markets tax conference · guglielmo maisto maisto e associati,...

A conference presented by the IBA Taxation Section

7th Annual IBA Finance & Capital Markets Tax Conference29–30 January 2018 etc. venues Fenchurch Street, London, England

Topics include:

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‘Excellent combination of networking and education.’

• Update on European and US global developments

• Interest deductibility – recent developments

• Financing – current issues and trends

• MLI – impact on tax planning

• Mergers and acquisitions

• Tax administration and tax advisors

• Funds update

• Multinational corporations – tax directors panel

• Transfer pricing

• Financial institutions

• Debt workouts

• Alternative outbound financial and investment structuring for US companies in post BEPS market

• Impact of BEPS and anti-avoidance rules on non-European/US countries

BOOK NOW AT WWW.IBANET.ORG/CONFERENCES/CONF856.ASPX UP TO 15½ CPD/CLE

HOURS AVAILABLE*

REGISTER BEFORE

15 DECEMBER 2017 TO RECEIVE

EARLY REGISTRATION

DISCOUNTS

http://www.ibanet.org/conferences/conf856.aspx

ProgrammeConference ChairJack Bernstein Aird & Berlis, Toronto

Organising CommitteeSandy Bhogal Mayer Brown, LondonFrancesco Capitta Macchi di Cellere Gangemi, Rome; Co-Chair, IBA Taxes CommitteeRaul-Angelo Papotti Chiomenti, Milan; Website Officer, IBA Individual Tax and Private Client CommitteeAlain Ranger Fasken Martineau DuMoulin, Montreal; Co-Chair, IBA Taxes CommitteeGordon Warnke KPMG, New York

• Bond issues – prospectus and tax representation• Listing of companies outside of home jurisdiction (mining

companies in Canada, UK, Fiat Chrysler, US inversion rules)• Crowdfunding• Notional interest regimes in Luxembourg, Belgium, Italy, Cyprus,

Switzerland and the Netherlands• US anti-abuse rules

Session ChairGuglielmo Maisto Maisto e Associati, Milan

SpeakersPaul Carman Chapman and Cutler, ChicagoJonathan Cooklin Davis Polk & Wardwell, LondonWerner Heyvaert Jones Day, BrusselsDean Kraus Stikeman Elliott, TorontoMark Leeds Mayer Brown, New YorkEric Wang Sullivan & Cromwell, London

ReporterLars Gläser Schindler Attorneys, Vienna

1130 – 1230

Mergers and acquisitions• Recent trends and transactions• Treaty shopping – new substance rules and principal purpose

test• M&A in Europe• CFC regimes with ATAD 1 and ATAD 2• Hybrid instruments – mismatch• UK hybrid rule• Out from under planning• Structuring private equity acquisitions – challenges after BEPS

and EU, financing, double tier structures, imported hybrid mismatches

• Spin off and public M&A• Impact of Brexit and US Tax Reform on inbound investments

Monday 29 January

0800 – 1800 Registration

0830 – 1000

Update on European and US global developments• Brexit: UK Repeal Bill – impact on cross-border investments and

financing• MLI – hybrid instruments and entities treaty shopping,

reservations and impact on existing treaties• EU – new directives (CRC rules, earnings stripping rules), ATAD 1

and ATAD 2• US – repatriation, territoriality and Trump tax reform• Comparison of US limitation of benefit treaty provisions and the

MLI

Session ChairStephen Edge Slaughter and May, London

SpeakersBernadette Accili LMS Studio Legale, MilanMargriet Lukkien Loyens & Loeff, Amsterdam; Corporate Counsel Forum Liaison Officer, IBA Taxes CommitteeEdward Wei Cadwalader Wickersham & Taft, New York

ReporterMarcel R Jung FRORIEP, Zurich

1000 – 1030 Coffee/tea break

1030 – 1130

Financing – current issues and trends• Impact of BEPS on financing structures (eg, arbitration clause,

anti-avoidance hybrids)• Availability of debt and new non-bank lending funds,

modification of non-debt• ECB guidelines on leverage

Headline social event sponsors

Monday continued

Session ChairSara Luder Slaughter and May, London

SpeakersGuillermo Canalejo Lasarte Uría Menéndez Abogados, Madrid; Conference Quality Officer, IBA Taxes CommitteeVictor Hollender Skadden Arps Slate Meagher & Flom, New YorkClemens Philipp Schindler Schindler Attorneys, ViennaBarbara Worndl Aird & Berlis, Toronto

ReporterDr Janusz Fiszer Gessel, Warsaw

1230 – 1330 Lunch

1330 – 1430

MLI – impact on tax planning• Financing structures• Holding companies• Intellectual property – patent boxes, royalty barrier• Impact on tax planning for US companies• Managing permanent establishment risk• Anti-abuse clauses (LoB clauses et al)

Session ChairFrancesco Capitta Macchi di Cellere Gangemi, Rome; Co-Chair, IBA Taxes Committee

SpeakersAilish Finnerty Arthur Cox, DublinReto Heuberger Homburger, Zurich; Scholarship Officer, IBA Taxes CommitteeJeffrey Trinklein Gibson Dunn & Crutcher, LondonAyzo van Eysinga AKD, Luxembourg

ReporterPierre-Antoine Klethi Loyens & Loeff, London


1500 – 1630

Interest deductibility – recent developments• BEPS Action 4 – interest barrier rule• EU – earnings stripping, anti-hybrids• UK – interest barrier rule• Limitation of group interest under regulation 385 IRC• Debt – equity characterisation, hybrid instruments

Session ChairChris Peters Willkie Farr & Gallagher, New York

SpeakersJessica Kemp Travers Smith, London

Peter Reinarz Bär & Karrer, ZurichJutta Schneider International and German Tax Law, Niddatal, Germany

ReporterAntti Lehtimaja Krogerus, Helsinki

1630 – 1830

Tax administration and tax advisors• Problems faced by tax administrations trying to administer

competitive tax systems in increasing hostile public environments• Reporting requirements and transparency (including CbCR,

mandatory disclosure of aggressive tax planning, responsibility of tax advisors, consequence of non-compliance of reporting requirements, protection of tax payer’s rights)

• Interaction between domestic anti-avoidance rules, tax treaty anti-abuse rules, EU directives and MLI

• Local and OECD promoted procedure of cooperation with tax authorities between authorities and companies to prepare the tax return and International Tax Audits

• Trends towards criminal remedies in attacking tax structures, consequences of the failure to prevent the facilitation of foreign tax evasion

• International tax dispute resolution (including MLI provisions as to disputes and arbitration, EU directive, treaty provisions)

• Update on state aid cases

Session ChairSam Kaywood Alston & Bird, Atlanta

SpeakersWalter H Boss Bratschi Wiederkehr & Buob, ZurichMichel Collet CMS Bureau Francis Lefebvre, ParisHeather Gething Herbert Smith Freehills, LondonWilhelm Haarmann Linklaters, FrankfurtJonathan Schwarz Temple Tax Chambers, LondonCarol P Tello Eversheds Sutherland, Washington DC

ReporterFrédéric Epitaux Oberson Abels SA, Lausanne

1845 – 1930 Drinks receptionThe Banking Hall, 14 Cornhill, London EC3V 3ND

This event is open to all delegates and registered guests.

1930 Conference dinnerThe Banking Hall

Ticket price: £90

Entry is by ticket only. Subject to availability.

Associate conference sponsor Conference luncheon sponsor

CMS_LawTax_RGB_from101.eps

Conference reception and dinner sponsor

Tuesday 30 January

0800 – 1800 Registration

0830 – 0930

Funds update• Fund formation• Carried interests• Impact of MLI on transparent entities• Impact of Brexit on funds• Impact of BEPS Action Plan 6• Holding company regimes, eg, UK, Luxembourg – substance,

principal purpose, LOB

Session ChairBrenda Coleman Ropes & Gray, London

SpeakersLars Jonsson Triton, LondonStuart Leblang Akin Gump Strauss Hauer & Feld, New YorkRebeca Rodriguez Martinez Cuatrecasas, MadridJean Schaffner Allen & Overy, Luxembourg

ReporterHarri Vehviläinen Hannes Snellman, Helsinki

0930 – 1030

Multinational corporations: tax directors panel• Group finance, cash pooling• Common reporting standards• Reporting requirements• Dividend repatriation• Trump proposals• Automatic exchange of rulings

Session ChairBarry J Quirke McDermott Will & Emery, Chicago

SpeakersMonica Cavallini Head of EMEA Group Taxation, FCA Fiat Chrysler Automobiles, MilanStuart Chessman Vivendi, New YorkJan Martin Baker Hughes, a GE Company, LondonNicholas Wheadon Johnson & Johnson, Reading

ReporterSonja Caymaz TP Week, London


1100 – 1200

Transfer pricing• Pricing methodologies including profit splits and latest OECD

guidance• Intercompany financing including debt capacity, cash pooling

and guarantees• Transfer pricing controversy and process including practical

experiences• The adoption into national laws and practice of BEPS Actions

8-10• Transfer pricing interface with diverted profits tax

Session ChairMurray Clayson Freshfields Bruckhaus Deringer, London

SpeakersPeter Blessing KPMG, New YorkPascal Hinny Lenz & Staehelin, ZurichBrian Lebowitz Alston & Bird, Washington DCRaul-Angelo Papotti Chiomenti, Milan; Young Lawyers’ Committee Liaison Officer, IBA Private Client Tax Committee

ReporterArnas Laurynas Quantera Global, London

1200 – 1300 Lunch

1300 – 1400

Financial institutions• Bank regulatory equity requirements and impact on tax

treatment (eg, no withholding tax, impact on participation relief calculation)

• Relocation of banking services from UK to Ireland and the continent

• CFC requirements for financial services• Holding companies of banking group, including impact of CoCo

when calculating participation exemption• New OECD VAT cross-border guidance• Automatic exchange of information data storage• CbCR reporting and its implementation• Tax treatment of bank recoveries

Session ChairMichael Nordin Schellenberg Wittmer, Zurich

SpeakersStefano M Ceccacci UniCredit Bank, MilanDaniel W Luchsinger Covington & Burling, Washington DCPeter Maher A&L Goodbody, DublinFederica Pitrone Intesa Sanpaolo, Milan

ReporterAndrew Cousins Duff & Phelps, London

Kindly supported byExhibitors

Tuesday continued

1400 – 1500

Debt workouts• Repayment of third party debt with debt (or equity) of other

affiliates• Intercompany loan restructuring• Guarantee issues• Cancellation of indebtedness considerations• Post-workout limitations on usage of net operating losses and

other tax attributes• Holder considerations

Session ChairGordon Warnke KPMG, New York

SpeakersAlbert Collado Garrigues, BarcelonaSean Finn Latham & Watkins, LondonStuart Goldring Weil Gotshal & Manges, New YorkSara Zablotney Kirkland & Ellis, New York

ReporterMichael J Fernando Jones Day, London


1530 – 1630

Alternative outbound financial and investment structuring for US companies in post-BEPS market• Alternative structures for hybrids• US inversions• Potential impact of Trump proposals

Session ChairRom Watson Ropes & Gray, Boston

SpeakersSandy Bhogal Mayer Brown, LondonKlaus Sieker Flick Gocke Schaumburg, FrankfurtJan van den Tooren Hamelink & Van den Tooren, The Hague

ReporterAlessandro Minniti Gianni Origoni Grippo Cappelli & Partners, Rome

1630 – 1800

Impact of BEPS and anti-avoidance rules on non-European/US countriesThis panel will review any domestic legislation in response to BEPS. It will also indicate whether a country has or is planning to sign the MLI. It will review the impact on structuring financing and M&A on both inbound and outbound transactions.

Session ChairClaire Kennedy Bennett Jones, Toronto; Treasurer, IBA Taxes Committee

SpeakersAseem Chawla Phoenix Legal, New Delhi; Secretary, IBA Taxes CommitteePeter Ni Zhong Lun Law Firm, Shanghai; Membership Officer, Asia, Australia, New Zealand, IBA Taxes CommitteeRaquel Novais Machado Meyer Sendacz e Opice Advogados, São PauloMonica Reyes Rodriguez Reyes Abogados Asociados, BogataAdrian Varrasso Minter Ellison, Melbourne

The IBA, its officers and staff accept no responsibility for any views expressed, presentations or materials produced by delegates or speakers at the Conference.

Continuing Professional Development/Continuing Legal Education

*The number of CPD/CLE hours available may vary depending on the rules applied by the members’ bar association/law society on time recording criteria.

For conference delegates from jurisdictions where CPD/CLE is mandatory, the IBA will provide a Certificate of Attendance for the conference. Subject to CPD/CLE requirements, this can be used by conference delegates to obtain the relevant number of hours’ accreditation.

A CPD/CLE Certificate of Attendance is available to conference delegates on request. Please ask at the IBA conference registration desk for information on how to obtain the certificate.

Kindly supported by

InformationDate29–30 January 2018

Venueetc.venues Fenchurch Street8 Fenchurch PlaceLondon, EC3M 4PBEnglandTel: +44 (0)20 3735 2700

LanguageAll working sessions and conference materials will be in English.

How to registerRegister online by 24 January at www.ibanet.org/conferences/conf856.aspx and make payment by credit card, to avail of the ten per cent online registration discount or complete the attached registration form and return it to the Conference Department at the IBA together with your bank transfer/cheque payment. You should receive emailed confirmation of your registration within five days; if you do not then please contact [email protected].

FeesOnline registrations received:

on or before until 15 December 24 January

IBA/IFA member £510 £600

Non-member* £645 £735

Young lawyers (under 30 years) £385 £735

Academics/judges (full-time) £385 £735

Public lawyers £385 £735

Corporate counsel** £460 £735

Guest £35 £35

Conference dinner £90 £90

After 24 January registrations must be received in hard copy at the IBA office.

Hard copy registration forms and fees received:

on or before after 15 December 15 December

IBA/IFA member £565 £665

Non-member* £715 £815

Young lawyers (under 30 years) £425 £815

Academics/judges (full-time) £425 £815

Public lawyers £425 £815

Corporate counsel** £510 £815

Guest £35 £35

Conference dinner £90 £90

* By paying the non-member fee, we welcome you as a delegate member of the IBA for the year in which this conference is held, which entitles you to the following benefits:

1) Password access to certain parts of the IBA website. 2) Receipt of IBA E-news and access to online versions of IBA Global Insight.3) Pay the member rate for any subsequent conference registrations for

this calendar year.** A reduced rate is offered to IBA Corporate Group Members. Please

register online to obtain a 25 per cent discount on the IBA member fee.

If you would like to become a full or general member of the IBA, which includes membership of one committee or more – and inclusion in and access to our membership directory – we encourage you to do so now in order to register for this conference at the member rate. Full details of how to join can be found at www.ibanet.org.

A reduced rate is offered to lawyers who are over the age of 65, have been an IBA member for more than 20 years and are no longer practising law.

Full payment must be received in order to process your registration.

Fees include:• Attendance at all working sessions• Conference materials, including any available speakers’ papers

submitted to the IBA before 19 January.• Access to the above conference working materials from the IBA website

(www.ibanet.org) approximately seven days prior to the conference• Access to mobile delegate search application • Lunch on Monday and Tuesday• Tea and coffee during breaks• Drinks reception on Monday• VAT at the current rate

Please note that registrations are not transferable.

Guest fees include:• Drinks reception on Monday

A guest must not be a member of the legal profession or seek to use the Conference as a business networking opportunity. Access to working sessions is not permitted for guests. Checks are made to ensure members of the legal profession are not registered as guests, if this is the case, registration will be refused unless the guest registers as a full delegate for the conference. Only registered guests (ie, those paying the guest fee) are eligible to participate in the social programme.

List of participantsIn order for your name to appear in the list of participants, which will be distributed at the conference, your registration form must be received by 24 January at the latest.

Mobile delegate search applicationAll registered delegates will receive a printed list of participants at the conference, however delegates are now also able to use the mobile delegate search. This application has been developed to aid networking by giving delegates instant access to an up-to-date list of their fellow attendees, and comes with the added benefit of a built-in messaging service. All registered delegates with an internet or Wi-Fi-enabled device will have access, using their IBA username and password. Simply visit: m.ibanet.org/conf856 Registration confirmation All documentation regarding your attendance at the conference can now be obtained from the IBA website. Upon receipt of your payment for the conference a confirmation email will be sent containing instructions on how to download the documents. Registration confirmation will not be distributed by post.



Photography and filmingCertain sessions and/or social functions may be photographed and/or filmed and some of this content may be used for future IBA marketing materials, member communications, products or services. Should you have any concerns with regard to this, or do not wish to be featured in any of these materials please contact the IBA Marketing Department at [email protected].

Promotional literaturePlease note that no individual or organisation may display or distribute publicity material or other printed matter during the conference, unless by prior arrangement with the IBA. Organisations and companies wishing to discuss promotional opportunities should contact the IBA Sponsorship Department at [email protected].

Payment of registration feesPounds sterling: by cheque drawn on a UK bank and in favour of the International Bar Association. Please send to: 4th Floor, 10 St Bride Street, London EC4A 4AD, United Kingdom.

OR by bank transfer to the IBA account number: 13270222 (Sort Code 56-00-03) at the National Westminster Bank, St James’s & Piccadilly Branch, 208 Piccadilly, London W1A 2DG, United Kingdom or SWIFT address NWBKGB2L, IBAN GB05NWBK56000313270222. Please ensure that a copy of the bank transfer details is attached to your registration form.

Euro: by cheque or bank draft, drawn on a euro zone bank and converted at the current rate of exchange and in favour of the International Bar Association.

OR by bank transfer to the IBA bank account number 550/00/06570631 (Sort Code 56-00-03) at the National Westminster Bank, St James’s & Piccadilly Branch, 208 Piccadilly, London W1A 2DG, United Kingdom or SWIFT address NWBKGB2L, IBAN GB58NWBK60721106570631. Please ensure that a copy of the bank transfer details is attached to your registration form.

Use the exchange rate prevailing at the time of registration.

US dollars: by cheque converted at the current rate of exchange and drawn on a US bank and in favour of the International Bar Association. Please send to: 4th Floor, 10 St Bride Street, London EC4A 4AD, United Kingdom.

OR by bank transfer to the IBA account number: 01286498 (Sort Code 56-00-03) at the National Westminster Bank, St James’s & Piccadilly Branch, 208 Piccadilly, London W1A 2DG, United Kingdom. SWIFT address NWBKGB2L, IBAN GB55NWBK60730101286498. Please ensure that a copy of the bank transfer details is attached to your registration form.

Use the exchange rate prevailing at the time of registration.

Online credit card payments: by Visa, MasterCard or American Express. No other cards are accepted.

Please ensure that your name and ‘CON856LONDON’ appear on any transfer or draft.

No deductions or withholdingsAll fees payable to us by you in accordance with the terms contained in this ‘Information’ section shall be paid free and clear of all deductions or withholdings whatsoever.

If any deductions or withholdings are required by law to be made from any fees payable to us by you under the terms contained in this ‘Information’ section you shall pay such sum as will, after the deduction or withholding has been made, leave us with the same amount as we would have been entitled to receive in the absence of any such requirement to make a deduction or withholding.

If we obtain the benefit of any tax credit or other relief by reference to any such deductions or withholdings, then we shall repay to you such amount as, after such repayment has been made, will leave us in no worse position than we would have been had no such deductions or withholdings been required.

Conference sell-outsThe IBA places its conference in venues of a suitable size for the event; however there are times when our conferences may sell out. Should this happen, prospective delegates will be informed and a waiting list will operate. The waiting list will function on a ‘first come, first served’ basis, subject to receiving registered delegate cancellations. The IBA will not be liable for any travel or accommodation expenses incurred by an individual who travels to the conference without a confirmed place at the event.

Cancellation of registrationIf cancellation is received in writing at the IBA office by 29 December, fees will be refunded less a 25 per cent administration charge. Refunds will be made minus any monies owed to the IBA.

We regret that no refunds can be made after this date. Registrations received after 29 December will not be eligible for any refund of registration fees. Please note that NO exception will be made to this policy. Should you have difficulties in obtaining your visa and are not able to attend the conference this cancellation policy will still apply.

Provided you have cancelled your registration to attend an IBA conference in accordance with the terms of the ‘cancellation of registration’ clause included in the ‘Information’ section of the relevant conference programme, you must then confirm to us in writing at the IBA office as soon as possible but in no event later than one year (12 calendar months) from the date of any such conference all necessary details to enable any reimbursement owed to you to be paid. We regret that no refunds will be made after the date that is one year (12 calendar months) after the date of the relevant conference.

Travel arrangements and visasParticipants are responsible for making their own travel arrangements. It is recommended that you check your visa requirements with your local embassy or consulate. We are unable to dispatch visa invitation letters to support your visa application prior to receipt of your registration form and full payment of registration fees.

Please apply for your visa in good time.

The organisers may at any time, with or without giving notice, in their absolute discretion and without giving any reason, cancel or postpone the conference, change its venue or any of the other published particulars, or withdraw any invitation to attend. In any case, neither the organisers nor any of their officers, employees, agents, members or representatives shall be liable for any loss, liability, damage or expense suffered or incurred by any person, nor will they return any money paid to them in connection with the conference unless they are satisfied not only that the money in question remains under their control but also that the person who paid it has been unfairly prejudiced (as to which, decision shall be in their sole and unfettered discretion and, when announced, final and conclusive).

Hotel accommodationBelow is a list of hotels located near etc.venues Fenchurch Street. Please contact the hotel of your choice directly to find out rates, availability and to make your reservation.

Apex City of London Hotel

1 Seething Lane, London, EC3N 4AXTel: +44 (0) 20 7666 1620www.apexhotels.co.uk/en.hotels.london/apex-city-of-london-hotel

Grange City Hotel

8-14 Copper’s Row, London, EC3N 2BQTel: +44 (0) 20 7863 3700www.grangehotels.com/hotels-london/grange-city

Four Seasons at Ten Trinity Square

10 Trinity Square, London, EC3N 4AJTel: +44 (0) 20 3297 9200www.fourseasons.com/tentrinity

hub by Premier Inn London Tower Bridge

28 Great Tower Street, London, EC3R 5ATTel: +44 (0) 871 527 9576www.premierinn.com/gb/en/hotels/england/greater-london/london/hub-london-tower-bridge.html

Unauthorised Accommodation AgentsIt has been brought to our attention that there are multiple companies contacting past attendees, claiming to represent the IBA, offering ‘assistance’ with registration and hotel bookings.

They are operating by cold-calling and spamming companies whose names have appeared on previous List of Participants, Programmes and Sponsorship recognition. The only Accommodation Agent the IBA works with is Judy Lane ICS. Judy Lane ICS do not contact delegates on behalf of the IBA without delegates making initial contact. Please ignore any communication that does not come directly from the IBA or Judy Lane ICS.

Disabled accessetc.venues Fenchurch Street is wheelchair accessible. Please notify us if you require special assistance. Social programme

Monday 29 January

1845 – 1930 Drinks receptionThe Banking Hall, 14 Cornhill, London EC3V 3ND

1930 Conference dinner The Banking Hall

Ticket price: £90

Entry is by ticket only.

Social event ticket reservations cannot be guaranteed unless payment has been received before 23 January, subject to availability.

A unique opportunity to learn with, and from, the best

King’s College London and the International Bar Association (IBA) have collaborated to offer an elite world-class professional LLM.

Designed to bring together wide-ranging legal perspectives and expertise from around the world, the Executive LLM aims to confront

some of today’s most challenging global legal issues.

This two-year, part-time advanced Master of Laws course is for ambitious commercial, in-house or regulatory lawyers, keen to build

on their achievements and develop their careers.

The Executive LLM offers a range of unique course content designed to equip you with advanced legal, commercial, and policy

knowledge as well as sectoral expertise. You will also develop complementary skills that will make you a more rounded, more

accomplished and more successful lawyer.

King’s College London & IBA

E X E C U T I V E L L MFor more information and how to apply:

Visit www.kcl.ac.uk/executivellm

Email [email protected]

Tel +44 (0)20 7848 5926

http://www.apexhotels.co.uk/en.hotels.london/apex-city-of-london-hotel

http://www.grangehotels.com/hotels-london/grange-city

http://www.fourseasons.com/tentrinity

http://www.premierinn.com/gb/en/hotels/england/greater-london/london/hub-london-tower-bridge.html

http://www.premierinn.com/gb/en/hotels/england/greater-london/london/hub-london-tower-bridge.html

Registration form

7th Annual IBA Finance & Capital Markets Tax Conference

29–30 January 2018, etc.venues Fenchurch Street, London, England

Please read the ‘Information’ section before completing this form and return it together with your bank transfer or cheque to the Conference Department at the address overleaf.

REGISTER ONLINE AT WWW.IBANET.ORG/CONFERENCES/CONF856.ASPX TO MAKE IMMEDIATE AND SECURE PAYMENT BY CREDIT CARD AND OBTAIN A 10 PER CENT DISCOUNT ON THE FEES BELOW

PERSONAL DETAILS (Please attach your business card or write in block capitals)

Title________________ Given name ____________________________________________ Family name _____________________________________________

Name and country to be shown on badge (if different from above) __________________________________________________________________________

IBA/IFA Membership number (if applicable) _____________________________________________________________ Date of birth ______________________

Firm/company/organisation_____________________________________________________________________________________________________________

Address ____________________________________________________________________________________________________________________________

_______________________________________________________________________________ Country ____________________________________________

Tel _____________________________________________________________ Fax ________________________________________________________________

Email ______________________________________________________________________________________________________________________________

Guest ______________________________________________________________________________________________________________________________ Guests are not entitled to attend the working sessions. No member of the legal profession may be registered as a guest.

SPECIAL DIETARY REQUIREMENTS

If you have special dietary requirements, due to allergen intolerances, medical, religious reasons or a life choice, please specify the requirement below. The IBA is unable to cater for dietary requirements other than for the above reasons.

Please tick box if you have allergen intolerances and specify ____________________________________________________________________________

Please tick box if your guest has allergen intolerances and specify _______________________________________________________________________

Please state all other dietary requirements clearly, i.e. I am a vegetarian; I do not eat red meat.

___________________________________________________________________________________________________________________________________

Disclosure of dietary information denotes you have agreed to the IBA sharing this information with relevant third parties who are providing catering on our behalf.

TO OBTAIN A TEN PER CENT DISCOUNT ON THE FEES BELOW, PLEASE REGISTER BY 24 JANUARY ONLINE AT WWW.IBANET.ORG/CONFERENCES/CONF856.ASPX

IBA/IFA MEMBERS CAN REGISTER ONLINE BY 15 DECEMBER FOR £510, PLEASE SEE ‘INFORMATION’ FOR FURTHER ONLINE REGISTRATION DETAILS.

HARD COPY REGISTRATION FORMS AND FEES RECEIVED: on or before 15 December after 15 December amount payable

IBA/IFA member £565 £665 £

Non-member* £715 £815 £

Young lawyers (under 30 years) £425 £815 £

Academics/judges (full-time) £425 £815 £

Public lawyers £425 £815 £

Corporate counsel** £510 £815 £

Guest £35 £35 £

http://WWW.IBANET.ORG/CONFERENCES/conf856.aspx


SOCIAL FUNCTION

Conference dinner Number of tickets __________ @ £90 £

One dinner ticket for each delegate and registered guest is permitted.Social function ticket reservations are subject to availability and cannot be guaranteed unless payment has been received before 23 January.

TOTAL AMOUNT PAYABLE £

*JOIN THE IBA TODAY AND REGISTER FOR THIS CONFERENCE AT THE IBA MEMBER RATE. PLEASE FIND THE MEMBERSHIP APPLICATION FORM AT WWW.IBANET.ORG.

**A REDUCED RATE IS OFFERED TO IBA CORPORATE GROUP MEMBERS. PLEASE REGISTER ONLINE TO OBTAIN A 25 PER CENT DISCOUNT ON THE IBA MEMBER FEE

A REDUCED RATE IS OFFERED TO LAWYERS WHO ARE OVER THE AGE OF 65, HAVE BEEN AN IBA MEMBER FOR MORE THAN 20 YEARS AND ARE NO LONGER PRACTISING LAW. PLEASE CONTACT THE IBA OFFICE FOR FURTHER INFORMATION.

FULL PAYMENT MUST BE RECEIVED IN ORDER TO PROCESS YOUR REGISTRATION. PLEASE NOTE THAT REGISTRATIONS ARE NOT TRANSFERABLE.

METHODS OF PAYMENT

By credit card

Register online at www.ibanet.org/conferences/conf856.aspx and make immediate and secure payment by credit card

Note: please do not send your credit card details on the registration form or within an email or fax.

By bank transfer and cheque/draft

Please send me an invoice.

I enclose a cheque/draft for the total amount payable.

I have transferred to the IBA bank account the total amount payable and have attached a copy of the bank transfer details.

Pounds sterling: by cheque drawn on a UK bank and in favour of the International

Bar Association. Please send to: 4th Floor, 10 St Bride Street, London EC4A 4AD,

United Kingdom.

OR by bank transfer to the IBA account number: 13270222 (Sort Code 56-

00-03) at the National Westminster Bank, St James’s & Piccadilly Branch, 208

Piccadilly, London W1A 2DG, United Kingdom or SWIFT address NWBKGB2L, IBAN

GB05NWBK56000313270222. Please ensure that a copy of the bank transfer details is attached to your registration form.

Euro: by cheque or bank draft, drawn on a euro zone bank and converted at the

current rate of exchange and in favour of the International Bar Association.

OR by bank transfer to the IBA bank account number 550/00/06570631 (Sort Code

56-00-03) at the National Westminster Bank, St James’s & Piccadilly Branch,

208 Piccadilly, London W1A 2DG, United Kingdom or SWIFT address NWBKGB2L,

IBAN GB58NWBK60721106570631. Please ensure that a copy of the bank transfer details is attached to your registration form.

[[Use the exchange rate prevailing at the time of registration.]]

US dollars: by cheque converted at the current rate of exchange and drawn on a US

bank and in favour of the International Bar Association. Please send to: 4th Floor, 10

St Bride Street, London EC4A 4AD, United Kingdom.

OR by bank transfer to the IBA account number: 01286498 (Sort Code 56-

00-03) at the National Westminster Bank, St James’s & Piccadilly Branch, 208

Piccadilly, London W1A 2DG, United Kingdom. SWIFT address NWBKGB2L, IBAN

GB55NWBK60730101286498. Please ensure that a copy of the bank transfer details is attached to your registration form.

[[Use the exchange rate prevailing at the time of registration.]]

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PLEASE SEND THE COMPLETED FORM TO INTERNATIONAL BAR ASSOCIATION:

Conference Department

4th Floor, 10 St Bride Street, London EC4A 4AD, United Kingdom

Tel: +44 (0)20 7842 0090 Fax: +44 (0)20 7842 0091 Email: [email protected] www.ibanet.org

http://www.ibanet.org


http://www.ibanet.org

The 2018 IBA Annual Conference will be held in Rome, the Eternal City. Founded nearly 3,000 years ago, the city is renowned for its ancient ruins, classical architecture, renaissance palazzos and baroque fountains. Rome is a vibrant, cosmopolitan city and will provide an elegant backdrop for the IBA Annual Conference.

Modern Rome is a major international business destination. It is the seat of the Italian government and the economy is dominated by services, IT, aerospace, defence and telecommunications companies, research, tourism, construction and banking. The city hosts the head offices of the vast majority of major Italian companies, as well as the headquarters of three of the world’s 100 largest companies, Enel, Eni and Telecom Italia.

As the saying goes, ‘all roads lead to Rome’ and it will indeed bring together delegates from all over the world for the largest and most prestigious event for international lawyers, providing an abundance of business and networking opportunities, not to mention the chance to explore one of the most fascinating cities on Earth.

WHAT WILL ROME 2018 OFFER YOU?• Gain up-to-date knowledge of the key developments in your area

of law which you can put into practice straight away

• Access to the world’s best networking and business development event for lawyers – attracting over 6,000 individuals representing over 2,700 law firms, corporations, governments and regulators from over 130 jurisdictions

• Build invaluable international connections with leading practitioners worldwide, enabling you to win more work and referrals

• Increase your profile in the international legal world

• Hear from leading international figures, including officials from the government and multilateral institutions, general counsel and experts from across all practice areas and continents

• Acquire a greater knowledge of the role of law in society

• Be part of the debate on the future of the lawTO REGISTER YOUR INTEREST:

Visit: www.ibanet.org/Form/IBA2018Rome.aspx

Email: [email protected]

To receive details of all advertising, exhibiting and sponsorship opportunities for the IBA Annual Conference in Rome, email [email protected]

OFFICIAL CORPORATE SUPPORTER

Advert space

International Bar Associationthe global voice of the legal profession

The International Bar Association (IBA), established in 1947, is the world’s leading organisation of international legal practitioners, bar associations, law firms and law societies. The IBA influences the development of international law reform and shapes the future of the legal profession throughout the world. It has a membership of more than 80,000 individual lawyers and more than 190 bar associations and law societies spanning over 160 countries.

Grouped into two divisions – the Legal Practice Division and the Public and Professional Interest Division – the IBA covers all practice areas and professional interests, providing members with access to leading experts and up-to-date information. Through the various committees of the divisions, the IBA enables and interchange of information and views among its members as to laws, practices and professional responsibilities relating to the practice of law around the globe. Additionally, the IBA’s world-class conferences provide unrivalled professional development a network building opportunities for international legal practitioners, senior business professionals, regulators and government officials.

Taxes Committee overviewThe IBA’s widely respected and very active Taxes Committee offers its members access to the highest quality technical, practical and professional tax expertise to assist in understanding and finding solutions to international tax issues and concerns. It also encourages interface between international tax specialists and promotes the building of networks among tax lawyers worldwide to assist them in better serving the interests of their clients. The committee is divided informally into four practice group areas: Income Taxes, Other Taxes, Tax Litigation and Employee Benefits.

Members are encouraged to contribute to the committee newsletter which is published two to three times per year and to present papers at committee conferences and seminars. The committee also offers tax executives a forum, in its Tax Executives group, to exchange expertise and skills with their colleagues in industry on topics of special interest

Contact informationInternational Bar Association4th Floor, 10 St Bride Street, London EC4A 4AD, United KingdomTel: +44 (0)20 7842 0090 Fax: +44 (0)20 7842 0091Email: [email protected] www.ibanet.org

2018

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Paul D. [email protected] ■ +1 312 845 3443

Paul focuses his practice on structuring tax consequences of finance and investment transactions and investment vehicles. Paul is an IBA member.

Attorney Advertising Material.

Charlotte Chicago New York Salt Lake City San Francisco Washington, DC chapman.com

US Counsel for Cross-Border FinanceChapman and Cutler LLP is one of the largest law firms in the United States dedicated to a financial services practice. We understand the evolving needs of financial services clients and skillfully combine legal acumen with business and market insight as we translate complex laws and regulations into practice advice.

Tax ExperienceWhen structuring cross-border transactions, our tax attorneys are familiar with foreign tax laws and understand the need to balance US and foreign tax law requirements, including negotiation of tax indemnity and other tax-oriented provisions.

■ US tax issues in cross-border finance and business operations

■ US taxation of domestic businesses abroad ■ US taxation of foreign businesses in the US ■ Pass-through structures for US tax purposes ■ Domestic and international not-for-profit and

501(c)(3) organization tax issues ■ Treaty interpretation ■ Foreign Investment in Real Property Tax Act issues ■ Offshore fund tax issues

Transaction ExperienceChapman has industry-leading practices in bank lending, structured finance and securitization, public finance, lease finance, private placement of debt securities, registered investment company funds, and bankruptcy and restructuring and regularly advises clients engaged in cross-border financial transactions.

■ Commercial Lending ■ Distressed Investments ■ Alternative Investments ■ Cross-Border Institutional Private Placements ■ Mergers and Acquisitions ■ Private Equity ■ Lease Finance ■ Ex-Im Bank Finance ■ High Net Worth Asset-Based Lending

Craig [email protected] ■ +1 212 655 2552

Craig advises clients on a broad range of U.S. tax issues, such as the taxation of capital markets transactions; cross-border financing; and FATCA.

Proud Sponsor

7th Annual

IBA Finance & Capital Markets Tax Conference

Patrick B. [email protected] ■ +1 212 655 2506

Patrick focuses his practice on structured finance and derivative products, encompassing virtually all of the CLO market.

Catherine Rossouw [email protected] ■ +1 212 655 2536

Cathy concentrates her practice on advising hedge fund and bank clients in private equity and lending transactions, including distressed investing and lender equity kickers.

2018

Con

fere

nce

Atte

ndee

s

Paul D. [email protected] ■ +1 312 845 3443

Paul focuses his practice on structuring tax consequences of finance and investment transactions and investment vehicles. Paul is an IBA member.

Attorney Advertising Material.

Charlotte Chicago New York Salt Lake City San Francisco Washington, DC chapman.com

US Counsel for Cross-Border FinanceChapman and Cutler LLP is one of the largest law firms in the United States dedicated to a financial services practice. We understand the evolving needs of financial services clients and skillfully combine legal acumen with business and market insight as we translate complex laws and regulations into practice advice.

Tax ExperienceWhen structuring cross-border transactions, our tax attorneys are familiar with foreign tax laws and understand the need to balance US and foreign tax law requirements, including negotiation of tax indemnity and other tax-oriented provisions.

■ US tax issues in cross-border finance and business operations

■ US taxation of domestic businesses abroad ■ US taxation of foreign businesses in the US ■ Pass-through structures for US tax purposes ■ Domestic and international not-for-profit and

501(c)(3) organization tax issues ■ Treaty interpretation ■ Foreign Investment in Real Property Tax Act issues ■ Offshore fund tax issues

Transaction ExperienceChapman has industry-leading practices in bank lending, structured finance and securitization, public finance, lease finance, private placement of debt securities, registered investment company funds, and bankruptcy and restructuring and regularly advises clients engaged in cross-border financial transactions.

■ Commercial Lending ■ Distressed Investments ■ Alternative Investments ■ Cross-Border Institutional Private Placements ■ Mergers and Acquisitions ■ Private Equity ■ Lease Finance ■ Ex-Im Bank Finance ■ High Net Worth Asset-Based Lending

Craig [email protected] ■ +1 212 655 2552

Craig advises clients on a broad range of U.S. tax issues, such as the taxation of capital markets transactions; cross-border financing; and FATCA.

Proud Sponsor

7th Annual

IBA Finance & Capital Markets Tax Conference

Patrick B. [email protected] ■ +1 212 655 2506

Patrick focuses his practice on structured finance and derivative products, encompassing virtually all of the CLO market.

Catherine Rossouw [email protected] ■ +1 212 655 2536

Cathy concentrates her practice on advising hedge fund and bank clients in private equity and lending transactions, including distressed investing and lender equity kickers.

Bloomberg BNATax & Accountingoffers breaking news, extensive coverage of major tax treaties, and:

• Practical analysis for developing complex international tax strategies

• Country-by-country analysis, including BEPS Tracker and VAT Navigator

• Targeted news and analysis

• International Tax Developments Tracker

• Practitioner-developed tools and resources

For a FREE trial visit www.bna.com/btax43

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Maisto e Associati is an independent Italian law firm specialised in tax law. Established in 1991 by lawyers with many years of experience in the field, Maisto e Associati has grown consistently in size and reputation and now has more than 40 professionals. With a proven

track record in tackling even the most complex cases, clients receive the benefit of years of experience combined with customized care and advice to the highest standard.

The firm as a whole and several partners individually have been consistently ranked for several years by independent researchers as tier 1 in the Italian tax scene (Chambers & Partners; The Legal 500; International Tax Review, World Tax). The firm was awarded as the best law firm in Europe for tackling cases before the European Court of Justice in direct tax matters (2011 International Tax Review Award “ECJ Firm of the Year – Direct Tax”).

Tax for M&A and corporate restructuring

Corporate and group taxation

Taxation of financial instruments

Real estate taxation

Tax planning for high net worth individuals

International and EU tax law

Transfer pricing

Tax litigation

Employee remuneration

VAT

Piazza F. Meda, 520121 Milanot +39 02.776931f +39 [email protected]

Piazza D’Aracoeli, 100186 Romat +39 06.45441410f +39 [email protected]

2,Throgmorton AvenueLondon EC2N 2DGt +44 (0)20.73740299f +44 (0)[email protected]

www.maisto.it

7th annual iba finance & capital markets tax conference · guglielmo maisto maisto e associati,...

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