Mourant

9th Annual IBA Finance & Capital Markets Tax Conference

20 Jan - 21 Jan 2020

Session information

Use of partnerships in cross-border transactions

Description

• Use of partnership and hybrid entities by multi- national corporations and investment funds in cross- border transactions • Tax treaties and their treatment of partnerships and hybrid entities • Recent legislative, regulatory and judicial developments • Recent challenges posed by the implementation of the anti-hybrid rules of the second European Union anti-tax avoidance directive (ATAD 2) for partnerships in both corporate and fund structures • Newly created traps for the unwary and double taxation risks in cross-border structures

Session / Workshop Chair(s)

Eric Sloan Gibson Dunn & Crutcher LLP, New York, New York, USA

Speakers

Jonathan Cooklin Davis Polk & Wardwell, London, England
Wiebe Dijkstra De Brauw Blackstone Westbroek, Amsterdam, Netherlands
Mariana Eguiarte Morett Garrigues, Mexico City, Mexico
Torsten Engers Flick Gocke Schaumburg, Frankfurt, Germany; Newsletter Editor, Taxes Committee
Bridget English Gibson, Dunn & Crutcher, London, England