US-Brazil Joint Meeting

 

 

 

 

Technical Program Topics Include:
• Acquisition and Sale of U.S. Companies by Brazilian Companies - Choice of Entity Decisions, Double Taxation Concerns, Brazilian CFC Issues, Repatriation of Earnings, etc.
• Tax Litigation in Brazil and in the United States - Navigating a Brazilian Tax System with Cases of Long Duration, High Tax Penalties, and No Formal Administrative Resolution Process (and Contrasting that System with the U.S. Tax System).
• Acquisition and Sale of Brazilian Companies by U.S. Companies - Choice of Entity, Amortization of Goodwill, FIP Structures, "Interest on Equity,” Debt/Equity Decisions, Thin Capitalization Rules, Holding Company Structures, etc.: (i) Large Company Deals; (ii) Private Equity Deals
• Special Topics on Transfer Pricing - The Effects of Brazilian Transfer Pricing in Business Restructurings and Ongoing Operations. Main differences between U.S. and Brazilian Rules.
• Ongoing U.S.-Brazil Tax Treaty Negotiations - Are the Differences In Positions Irreconcilable?: The Panel Will Address Issues Such as Article 7, Withholding Tax Rate Reductions, Credit Sparing, Tax Information Exchange, Etc.
• New Brazilian Concepts of Tax Blacklisting - Analyzing the New Concept of the Brazilian "Tax Haven.” Will the Delaware LLC and LLCs in Other US States Ultimately Be Affected? What Alternative Structures Are Being Considered By Inbound Investors?
• Distribution of Goods and Supply Chain Management Strategies - Addressing Various Supply Chain/Distribution Models to Access the Brazilian and U.S. Markets with Special Focus on Models that Combat High Brazilian Import Taxes.
• Special Topics in Licensing Into Brazil and Into the United States - Exploring the Unique Brazilian Rules that Impose Major Restrictions on the Ability of Most U.S. Multinational Corporations to Utilize Simple Licensing Models; Exploring Alternative Structures When Attempting to Import Technology into Brazil and the United States.
• Tax Treaty Workshop - Discussing Compromise Proposals for Both Countries to Improve the Environment for Continuing Bilateral Treaty Negotiations—Open Q&A and Commentary

 

 

 

 

 

Registration:
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Registration is now open - use the link on this page menu to register online, or click here for a hard copy registration form.

 

 

 

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Ritz-Carlton Key Biscayne Hotel A block of guestrooms has been reserved at the Ritz-Carlton Key Biscayne Hotel. Please make your reservation right away! All participants are required to make their own accommodation arrangements directly with the hotel. Rooms will be filled on a first-come/first-serve basis, and unbooked rooms (if any) will be released for general sale on April 23, 2010. The special group rate will not be available after that time.

IFA Group Rate: $259.00 standard room Phone Reservations: +1-305-365-4500 Please request the group rate for International Fiscal Association Online reservations: https://www.ritzcarlton.com/en/Properties/KeyBiscayne/Reservations/Default.htm Group Code for IFA Conference is: IFAIFAA