Session details

The New Era of Taxation: how to remain on top in a world in constant evolution

30 Nov - 1 Dec 2017

Hilton Buenos Aires Hotel

Session information

Ignorance of foreign law might not be a defence: Legal challenges for tax advisors in international transactions
Hilton Buenos Aires Hotel


Legal Practice Division (Lead)
Taxation Section (Lead)
Taxes Committee (Lead)


As governments are becoming more keen to attack firms’ aggressive tax strategies, tax advisors are coming into the crosshairs. This session will consider enforcement trends as they affect advisors, and will discuss issues including: (1) can tax avoidance or tax evasion limit attorney-client privilege, and where is the line drawn? In particular, are countries levying sanctions against taxpayers and their advisors for planning what used to be considered standard? (2) what obligations do tax advisors have to investigate client activities and law in foreign jurisdictions when they know there is international planning, even if the advisor is only providing local-country advice? (3) tax advisors have been held jointly liable for their clients’ tax deficiencies, particularly in contingent/success fee arrangements. When might this liability apply? Session Co-Chairs Annabelle Bailleul Mirabaud, CMS Bureau Francis Lefebvre, Neuilly-sur-Seine Roberto Duque Estrada, Xavier Duque-Estrada Emery Denardi Advogados, Rio de Janeiro; International Organisations Liaison Officer, IBA Taxes Committee Speakers Valerio Cirimbilla, Macchi di Cellere Gangemi, Rome Nicholas Gardner, Ashurst, London Summer LePree, Bilzin Sumberg Baena Price & Axelrod, Miami Rocio Liu, Miranda & Amado Abogados, Lima Agustina Suarez, Ippoliti Passarella Abogados, Buenos Aires

Session / Workshop Chair(s)

Annabelle Bailleul-Mirabaud CMS Francis Lefebvre Avocats, Neuilly-sur-Seine, France
Roberto Duque-Estrada Brigagão Duque-Estrada Advogados, Rio de Janeiro, Brazil; International Organisations Liaison Officer, Taxes Committee