9th Annual IBA Finance & Capital Markets Tax Conference
20 Jan - 21 Jan 2020
Session information
Passive investment companies: new developments and strategies to address deferral
Monday 20 January (1130 - 1230)
Description
• Update on new USA passive foreign investment company (PFIC) regulations, over 30 years in the making • Why these rules are relevant to foreign issuers in the USA capital markets and beyond • Regimes used by other countries (Australia, France, Spain, and the UK) to address deferral of passive investment income o Controlled foreign corporation (CFC) rules, which require control to be effective o Taxation and regulation of investment funds • Discuss the differences among countries’ approaches to dealing with the deferral of investment income
Session / Workshop Chair(s)
| Kimberly Blanchard | Retired, New York, New York, USA |
Speakers
| Peter Blessing | Internal Revenue Service, Washington, District of Columbia, USA |
| Guillermo Canalejo Lasarte | Uria Menendez, Madrid, Spain |
| Olivier Dauchez | Gide Loyrette Nouel A.A.R.P.I., Paris, France |
| Alan Sournac | Gide Loyrette Nouel, Paris, France |
| Andrew Thomson | Sullivan & Cromwell LLP, London, England |
| Hamish Wallace | MinterEllison, Sydney, New South Wales, Australia |