US-Brazil Technical Program

 

 

 

 

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.
• Brazilian Tax Litigation - Navigating a Tax System with Cases of Long Duration, High Tax Penalties, and No Formal Administrative Resolution Process
• 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
• Brazilian Transfer Pricing Rules - The Effects of Brazilian Transfer Pricing in Business Restructurings and Ongoing Operations
• 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 into Brazil and Supply Chain Management Strategies - Addressing Various Supply Chain/Distribution Models to Combat High Brazilian Import Taxes
• Licensing Into Brazil - Exploring a Tax System that Imposes Major Restrictions on the Ability of Most U.S. Multinational Corporations to Utilize Simple Licensing Models in Brazil and Exploring Alternative Structures When Attempting to Import Technology into Brazil
• 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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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