Global Tax Enforcement Conference

Transcription

1 Global Tax Enforcement Conference Friday, 11 September 2015, Villa Marina, Douglas, Isle of Man Event Schedule Page 2 Why You Should Attend What You Will Learn Who Should Attend Speaker Biographies Links Speakers Brian McManus Partner, Latham & Watkins LLP, Washington, D.C., United States Phil Morris Member of IOM FATCA working party and Tax Senior Manager at PWC, Isle of Man Chad Nardiello Partner, Nardiello Law Firm Plc, California, United States Tom Maher Managing Partner, DQ Advocates, Isle of Man Neal H Levin Partner, Freeborn & Peters LLP, Chicago, United States Fiona Fernie Partner, Tax Investigations, Pinsent Masons, UK Ian Bancroft Member of IOM FATCA working party and MD of Cayman National, Isle of Man Annemarie Hughes Partner and Head of Trusts & Private Client, DQ Advocates, Isle of Man Sinead O Connor Head of Regulatory & Compliance Services, DQ Advocates, Isle of Man Additional speakers to be confirmed Page 1

2 EVENT SCHEDULE Friday, 11 September 2015, Villa Marina, Isle of Man 10:30-11:00 a.m. Registration & Coffee 11:00-11:15 a.m. Welcome and Opening Remarks Co-Chairs Brian McManus & Tom Maher 11:15-12:15 p.m. Automatic Exchange of Information in practice Update on US & UK FATCA and the practicalities of compliance; look ahead to Common Reporting Standard; and consideration of the implications of BEPS for offshore business 12:15-1:30 p.m. Lunch Break Sponsored by Pinsent Masons. 1:30-2:15 p.m. The Psychology of Fraud from Neanderthal to Madoff Understanding the psychology of a fraudster is your client a fraudster or a tax dodger? Neal H Levin, Freeborn & Peters LLP 2:15-3:00 p.m. Automatic Exchange of Information the consequences for IOM businesses Ramifications of a TIEA request straightforward v complex and the challenges involved where the request is complex; AML issues including disclosure and possible further enquiry from the FCU; the impact of Swiss leaks; managing varying obligations including client confidentiality, regulatory responsibilities and fiduciary duties Ian Bancroft, Member of IOM FATCA working party Phil Morris, Member of IOM FATCA working party Annemarie Hughes, DQ Advocates 3:00-3:15 p.m. Coffee Break Page 2

3 EVENT SCHEDULE 3:15-4:15 p.m. When AEOI leads to a tax investigation The approach of HMRC and the IRS to tax investigations the tools they have to make sense of the information you provide; recent case history and lessons learned; the challenges that IOM businesses may face Chad Nardiello, Nardiello Law Firm Neal H Levin, Freeborn & Peters LLP 4:15-4:45 p.m. Tax & criminal investigations what we can expect in the future Anticipated developments in the HMRC and IRS regimes including the impact of the Swiss and other bank disclosure initiatives, recent commitments given by the UK government to increase transparency and counteract corruption, HMRC s new powers to tackle tax evasion and avoidance as well as new HMRC criminal and civil sanctions and their impact on offshore business Chad Nardiello, Nardiello Law Firm 4:45-5:15 p.m. Questions 5:15 p.m. Cocktail Reception Sponsored by DQ Advocates and Latham & Watkins LLP Page 3

4 EVENT INFORMATION Why You Should Attend The goal of this conference is to provide delegates with an understanding of how international governments pursue tax investigations, what best practices you can implement on a going forward basis and the implications of various strategies for handling and meeting the challenges of an investigation. The ultimate purpose is to demystify tax investigations and arm the delegate so that when an enforcement proceeding begins, a feeling of rational calmness will replace what otherwise would have been anxiety and a creeping sense of panic. Most financial services industry executives would like to focus on one goal: expanding their business. That ambition usually contemplates offering new services and/or enlarging the business footprint across new borders. Executives are not expected to be steeped in the know-how and complexities of confronting an international tax investigation, and for the most part would prefer to avoid such matters. However, the reality is that the likelihood of having to encounter a global tax investigation is on the rise. We are standing at the foot of an inexorable upward curve in global tax enforcement. With compliance with US and UK FATCA becoming business as usual and a commitment to implementing the Common Reporting Standard, the number of global tax and criminal cross border investigations is going to rise significantly. Previously confidential information is now at the fingertips of most tax authorities and if you haven t already received a TIEA request for disclosure or been involved in a tax investigation, then it is only a matter of time. A business can no longer choose the path of passive ignorance. With the increase in exchange of information and transparency comes an increased risk that clients or potential clients may seek to engage in activities which would contravene tax transparency laws. The conference will, therefore, include an important focus on steps that businesses can take to mitigate against the risk of becoming involved in criminality and fraud at client level. The conference will serve as a stimulating discussion in an open environment which will encourage delegates to think, learn, exchange views and network. Steered by pan-industry experts, the conference will offer valuable insights through panel discussions at which your questions can be answered, as well as at lunch and networking breaks, and a reception at the conclusion of the day s panels. What You Will Learn Topics include: Current views on automatic exchange of information Tax investigations from IOM, UK and US perspectives Practical steps you should take in meeting the challenges presented by global tax enforcement Strategic implications of varying approaches in responding to requests for information Whether to allow and how to prepare for interviews by investigators Considerations for producing documents to investigators Whether the client s funds can be used to hire legal representation and important AML issues Reconciling your duties to the client with issues of self-preservation and regulatory duties

5 EVENT INFORMATION Who Should Attend This conference is aimed specifically at senior management, MLROs and compliance officers within financial services industries such as: Fiduciaries Banks Insurance Companies Fund and Investment Companies Accountants Lawyers This conference will provide practical and commercially relevant guidance to financial services businesses dealing with international tax, fraud and criminal investigations involving their clients or related parties. We will provide background on global tax enforcement, as well as guidance on the best practices and strategies to adopt before and after you are contacted by foreign tax or criminal authorities. We aim to help you be ready to meet the challenges posed in this new era of heightened cross-border enforcement. Speaker Biographies Please see for full details of the speakers biographies and expertise. Links For further information on DQ, please visit For further information on Latham & Watkins LLP, please visit