Current International Tax Issues in Cross- Border Corporate Finance and Capital Markets
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1 Presented by the International Bar Association, Tax Section in association with the Chartered Institute of Taxation European Branch Current International Tax Issues in Cross- Border Corporate Finance and Capital Markets May 2011 Whitefriars Lecture Theatre Freshfields Bruckhaus Deringer LLP 65 Fleet Street London EC4Y 1HS
2 Programme Conference Co-Chairs Jack Bernstein Aird & Berlis LLP, Toronto (IBA) Jonathan Schwarz Temple Tax Chambers, London (CIOT) Monday 16 May Tuesday 17 May Registration of delegates Interest Deductibility Current State of Play and Direction of Travel Murray Clayson Freshfields Bruckhaus Deringer LLP Michel Collet CMS Bureau Francis Lefebvre; Website Officer, IBA Taxes Committee John Sherman HM Treasury Financing Transactions in this Environment including Securitizations Patrick Mears Allen & Overy Paul Carman Chapman & Cutler LLP Peter Maher A & L Goodbody Coffee and Tea Break Hedging Including Credit Default Swaps and Managing Foreign Exchange Issues Carlos Ferrer Cuatrecasas Goncalves Pereira Erika Nijenhuis Cleary Gottlieb Justin Hamer Greenberg Traurig LLP Taxation of Offshore Income of Financial Institutions (CFC Rules, Managing Foreign Tax Credits) Richard Hartnig Sutherland Asbill & Brennan LLP Pano Pliotis GE Capital Erica Gut Bank of America Merrill Lynch 1845 Cocktails (all delegates welcome) Crowne Plaza Hotel (London The City) New Bridge Street EC Dinner* Crowne Plaza Hotel (London The City) New Bridge Street EC4 *A separate charge of 60 will be made Use of Finance Companies by Multinationals Carmine Rotandaro Gucci Sara Luder Slaughter and May Klaus Sieker Flick Gocke Schaumburg Marcel Buur Loyens & Loeff Michael Lukacs GE Capital Coffee and Tea Break Capital Raising for Banks Under Regulatory Constraint Yash Rupal Linklaters Michael Nordin Schellenberg Wittmer Jen Zheng CITI Bank Jonathan Winstanley Lloyds Banking Group Withholding and Reporting Compliance Issues (Including FATCA and Beneficial Ownership) Andrew Solomon Sullivan Cromwell Rom P Watson Ropes & Gray LLP Buffet Lunch Current Trends in Structured Finance including impact of GAAR Heather Gething Herbert Smith LLP Eric Chun Ernst & Young Chris Bates Norton Rose LLP Stephen Hoyle DLA Piper UK LLP Coffee and Tea Break Distressed Debt Issues Simon Yates Travers Smith LLP; Newsletter Editor, IBA Taxes Committee Fernando Casanueva Garrigues Christophe Joosen Nauta Dutilh Mark Weinstein Hogan Lovells LLP
3 Information Date May 2011 Conference Venue Whitefriars Lecture Theatre Freshfields Bruckhaus Deringer LLP 65 Fleet Street London EC4Y 1HS Cocktails and Dinner Venue Crown Plaza Hotel (London The City) 19 New Bridge Street London EC4V 6DB Language All working sessions and conference materials will be in English. How to Register Please complete the attached registration form and to Melissa Lawrence at Payment to be made by major credit card to be included when registering. You will receive an confirmation and invoice. Registration Confirmation Upon receipt of your payment for the conference, a confirmation will be sent containing instructions on how to download conference materials prior to the event. Registration confirmation will not be distributed by post. Hotel Accommodation Hotel rooms have been held at The Crowne Plaza Hotel (London The City) at the rate of 205. This price is per room/ night, includes breakfast and is subject to VAT 20%. In case of changes to the VAT, currently 20%, the hotel reserves the right to adjust the prices. A 10 supplement for double of occupancy will be made. Please make your reservations directly with the hotel by 17 April 2011 to secure this rate. Group code: SB3 Reservations can be made via: Website: loncy.groups@ihg.com Telephone: 44 (0) Fees The conference fee set out below includes the cocktail party. There is an additional charge of 60 for the dinner on Monday 16 May IBA Member/CIOT Member* Early Bird (before 1 April 2011) 195 Regular 225 *Join now and benefit from discount Non IBA Member/CIOT Member Early Bird (before 1 April 2011) 235 Regular 250 Delegate Fees include: Attendance at seminar Access to conference materials online Business lunch on 17 May 2011 Tea and coffee during breaks Cocktail reception at Crowne Plaza Hotel London
4 Registration Form Current International Tax Issues in Cross-Border Corporate Finance and Capital Markets May 2011, Whitefriars Lecture Theatre, Freshfields Bruckhaus Deringer LLP, London To register please send this form via to or via fax to Full payment must be received in order to process your registration. 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/CIOT membership number (if applicable) Date of birth Firm/Company/Organisation Address Tel Fax Registration form and fees received: Early Bird Regular Amount payable (before 1 April 2011) IBA/CIOT member Non IBA/CIOT member Social functions Yes, I will attend the dinner 60 ticket price No, I will not attend the dinner Please let us know if you have any dietary requirements/allergies Hotel Will you be booking your room at the Crown Plaza Hotel London TOTAL AMOUNT PAYABLE Payment details Please charge the total amount due to my (delete as appropriate) Visa/MasterCard/American Express. Other cards are not accepted. Card number Start date Expiry date Name of cardholder Signature Date
5 International Bar Association the 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 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 40,000 individual lawyers and 197 bar associations and law societies spanning all continents. It has considerable expertise in providing assistance to the global legal community. Divisions and committees 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 an interchange of information and views among its members as to laws, practices and professional responsibilities relating to the practice of business law around the globe. Taxes Committee overview The 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. Additionally, the Taxes Committee works with the Individual Tax and Private Client committee to form the Taxation Section Contact information: International Bar Association 10th Floor, 1 Stephen Street, London W1T 1AT, United Kingdom Tel: +44 (0) Fax: +44 (0) Chartered Institute of Taxation The CIOT is the leading body in the UK for taxation professionals dealing with all aspects of taxation. Our primary purpose is to promote education in taxation. One of our key aims is to achieve a more efficient and less complex tax systems for all. Our comments and recommendations on tax issues are made solely in order to achieve this aim; we are an entirely apolitical organisation. Membership of the CIOT is by examination; nationally recognised as the gold standard of UK taxation education. We support our 15,000 members and 4,000 students throughout their tax careers, providing assistance through our London-based head office and worldwide network of 34 branches. The CIOT is a registered charity, number and a regulatory body for the purposes of Anti-Money Laundering supervision of tax practitioners.
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