Spring 2015 International Financial Services Business Briefings

Transcription

1 Zurich Spring 2015 International Financial Services Business Briefings Following are our Business Briefings through June 2015: Non-US residents and citizens investing in US real property Date: Thursday, 22 January 2015 Devan Patrick, Baker & McKenzie Zurich James Scears, Baker & McKenzie Zurich The United States real property market presents valuable investment opportunities for both individual and corporate investors. However, the purchase and sale of property may trigger complex US tax obligations and reporting requirements, particularly for individuals who desire to spend significant amounts of time in the United States using their property. Join us for a discussion focusing on the general taxation of non-us persons who are considering investing in US real property, both directly and through various investment entities. International succession planning and marital property Date: Thursday, 5 February 2015 Elena Zafirova, Baker & McKenzie Zurich Jacopo Crivellaro, Baker & McKenzie Zurich We live in a world where families are increasingly international and have connections to many jurisdictions. This session will provide an overview of matrimonial property and succession laws, mainly focusing on Europe and the Americas. What are the main changes of EU Regulation No. 650/2012? What do you need to watch out for? The Wealth Management and Insurance Practice Groups of Baker & McKenzie Zurich would like to invite you to a series of Business Briefings on issues relevant to the Swiss private banking and insurance communities. All sessions will be conducted in English unless otherwise noted. For additional information on the substance of these programs, please contact: Marnin Michaels Tel.: marnin.michaels@bakermckenzie.com For logistical information, please contact: Elizabeth Stocker Tel.:

2 Common Reporting Standards and White Money Policy: How do you get ready? Date: Tuesday, 17 February 2015 Marnin Michaels, Baker & McKenzie Zurich Whether it is 2017, 2018 or 2020, Common Reporting Standards (CRS) - or global FATCA - is coming. While there is much focus on CRS, the issue of how this intersects with an institution s White Money Policy is not often discussed. This session will take a look at the preparatory steps an institution must consider when organizing the two issues together. Mr. Michaels will cover lessons learned from experiences with the US, UK, France, Germany and Israel and how those lessons can be used to create a proactive strategy. AIE Reporting and Domestication of non-us Trusts and Foundations with US Beneficiaries Date: Tuesday, 10 March 2015 Gregory Walsh, Baker & McKenzie Zurich Danilo Santucci, Baker & McKenzie Zurich This session will address reporting in respect of trusts and foundations for US tax, financial reporting and FATCA purposes, as well as OECD CRS automatic information exchange (AIE). In light of today s increased compliance obligations and costs, professional fiduciaries may wish to transfer structures with US-person beneficiaries to the United States. This session will also examine the consequences of such structures to US beneficiaries and the costs and benefits of potential mitigation strategies. Update on insurance and insurance brokerage laws Date: Tuesday, 17 March 2015 Joachim Frick, Baker & McKenzie Zurich Anette Waygood-Weiner, Baker & McKenzie Zurich The session will focus on the latest version of the draft Financial Services Act, the critical comments it received, and other recent legal developments significantly affecting the Swiss insurance and insurance brokerage market. Special attention will be given to the (controversial) rules affecting market access and the relation between Switzerland and the EU. Anti-avoidance rules for US non-resident investors in foreign entities (CFCs, PFICs) Date: Thursday, 26 March 2015 Thomas Salmon, Baker & McKenzie Zurich Ella Campi, Baker & McKenzie Zurich Many international private banking clients use a combination of trusts and companies to hold their international assets. During their lifetime, many such clients retain a power to revoke their trust. Many such clients also want their trusts to continue after death, but in an irrevocable form. 2

3 In today s global environment, these clients will have children or grandchildren who are US taxpayers. When a trust holding company transitions from a revocable to an irrevocable trust after a client dies, the usual problems associated with a foreign non-grantor trust with US beneficiaries can be exacerbated when the underlying companies would qualify as Controlled Foreign Corporations (CFC) or Passive Foreign Investment Companies (PFICs). Ella Campi and Thomas Salmon will review some of the more prominent issues and suggest solutions for minimizing problems for the next generation. Latest developments in the French tax legislation impacting wealth management Date: Thursday, 16 April 2015 Stéphanie Auferil, Baker & McKenzie Paris This briefing will focus on latest developments in the French tax legislation impacting wealth management, including a discussion on trust reporting issues, as well as on the ongoing developments regarding tax and criminal risks for French taxpayers and their advisors (financial institutions, trustees, etc.). In the context of international coordination against tax fraud, Ms. Auferil will provide background and solutions to deal with French residents (voluntary procedures, exit tax, etc.). Liability risks of heirs: risk assessment and mitigation of tax exposure after the death of the decedent Date: Tuesday, 21 April 2015 Robert Desax, Baker & McKenzie Zurich Sabine Herzog, Baker & McKenzie Zurich Swiss inheritance law is based on the principle of the Universalsukzession which means that on death of the deceased, the estate in its entirety vests by operation of law in the heirs. As a consequence, the debts of the deceased become the personal debts of the heirs and they are jointly and severally held liable for debts of the decedent. The immediate question for the heirs is, therefore, whether they should accept an inheritance together with all its (potential) liabilities or whether they should disclaim the inheritance passing to them. This session will focus on how to evaluate benefits and risks of accepting an inheritance, how to address potential tax issues (such as tax regularization of the decedent or inheritance taxes), and how to manage other liability concerns. We will also discuss typical problems that may arise in cross-border situations. Implementation of the Russian Deoffshorization Campaign Date: Tuesday, 12 May 2015 Sergei Zhestkov, Baker & McKenzie Moscow This session will cover tax and legal issues relating to the implementation of the Russian Deoffshorization Campaign, including new limitations on the currency control and reporting for cross-border transactions, new CFC rules and anti-abuse tax provisions (corporate tax residency, beneficial ownership) and other relevant topics. 3

4 Regulatory developments and FINMA practice relevant to the private banking and asset management industry Date: Thursday, 28 May 2015 Markus Affentranger, Baker & McKenzie Zurich Theo Härtsch, Baker & McKenzie Zurich This session will provide an overview of recent regulatory developments and FINMA practice relevant to private banking and asset management. The respective topics will mainly be the developments towards the contemplated Financial Services Act and Financial Institution Act, the implementation of the recommendation of the FATF for transparency and prevention of money laundering and findings and issues related to the Collective Investment Scheme Act. UK developments and planning Date: Tuesday, 9 June 2015 Stephanie Jarrett, Baker & McKenzie Geneva Lyubomir Georgiev, Baker & McKenzie Zurich This periodic briefing will again address the status of HMRC proposals and consultations as well as updates relevant to UK taxation and succession planning arising out of the UK 2015 Budget, and the likely implications arising from the UK parliamentary election in May Among the key issues and recent experiences expected to be discussed will be: IHT & multiple-trust anti-avoidance measures, GAAR penalties, DOTAS transparency, offshore tax evasion penalties, UK BEPS, US & UK FATCA, EU DAC, LDF, and UK s withholding agreement with Switzerland. We will also assess the progress on beneficial ownership transparency and registry as well as comment on expected future UK developments in wealth management and taxation. Investing in Spanish real estate and recent developments affecting the wealth management industry Date: Thursday, 25 June 2015 Esteban Raventos, Baker & McKenzie Barcelona This briefing will focus on investing in Spanish real estate and recent relevants developments affecting the wealth management industry. 4

5 Reply Slip International Financial Services Business Briefings Please use one reply slip for each person attending. Photocopies of the reply slip are acceptable. Please respond as soon as possible and write in block letters. Thank you! Last Name, First Name: Position/Title: Company: Address: Postal Code/City: Telephone: address: I would like to attend the following Business Briefing/s: 0 22 January 2015 Non-US residents and citizens investing in US real property 0 5 February 2015 International succession planning and marital property 0 17 February 2015 Common Reporting Standards and White Money Policy: How do you get ready? 0 10 March 2015 AIE Reporting and Domestication of non-us Trusts and Foundations with US Beneficiaries 0 17 March 2015 Update on insurance and insurance brokerage laws 0 26 March 2015 Anti-avoidance rules for US non-resident investors in foreign entities (CFCs, PFICs) 0 16 April 2015 Latest developments in the French tax legislation impacting wealth management Please send this reply slip to: Baker & McKenzie Zurich Holbeinstrasse 30 P.O. Box 8034 Zurich Attention: Elizabeth Stocker businessbriefings.zurich@bakermckenzie.com Venue: Hotel Glockenhof Sihlstrasse Zurich Switzerland 0 Materials only - by (please ü this box and indicate the dates in the left-hand column) Please note that you will receive a reminder shortly before the event. This also serves as confirmation of your registration. Kindly respond if you are unable to attend. While there is no charge for attending any of these sessions, given the costs of our venues and the limited space available, we are required to charge a fee of CHF for any cancellation of a reservation, reservations made within 48 hours of a session, or people who make a reservation, but fail to attend ( no-show charge ). For those who are not able to attend a briefing, there continues to be no charge to receive a copy of the materials by April 2015 Liability risks of heirs: risk assessment and mitigation of tax exposure after the death of the decedent 0 12 May 2015 Implementation of the Russian Deoffshorization Campaign 0 28 May 2015 Regulatory developments and FINMA practice relevant to the private banking and asset management industry 0 9 June 2015 UK developments and planning June 2015 Investing in Spanish real estate and recent developments affecting the wealth management industry 2015 Baker & McKenzie. All rights reserved. Baker & McKenzie International is a Swiss Verein with member law firms around the world. In accordance with the common terminology used in professional service organizations, reference to a partner means a person who is a partner, or equivalent, in such a law firm. Similarly, reference to an office means an office of any such law firm. This may qualify as Attorney Advertising requiring notice in some jurisdictions. Prior results do not guarantee a similar outcome. 5