9th Annual IBA Finance & Capital Markets Tax Conference
20 Jan - 21 Jan 2020
Session information
Description
• Taxation on gains and disposition in Canada • Withholding tax on rental income in Canada • Insertion of a Canadian blocker or s.216 election • Use of Canadian REIT to own USA real estate • Interest deductions and thin capitalisation rules in Canada • Gain taxation on transfer of shares in real estate companies • Real estate security and taxation of interest • New rules regarding real estate transfer tax (RETT) blocker structures in Germany • Use of Luxembourg for real estate investments in France, Germany and the UK (Luxembourg) • Interest deduction limitation rules in Luxembourg • Treatment of dividends and gains on investments by foreign funds for real estate investments in Spain • Real estate investments through regular companies in Spain • Real estate investments through REIT (SOCIMI) in Spain • Limitations on deducibility of interest in Spain • Shares versus asset acquisitions: tax issues in Spain • Commercial real estate investment post-Tax Cuts and Jobs Act of 2017 in the USA • Current income and withholding taxes on ownership and operation in the USA • Trade of business election in the USA • Interest limitation election in the USA • Branch profits and branch interest in the USA • Taxation of gains for foreign investment in property in the USA • Exemptions for qualifies foreign pension plans in the USA • Domestically controlled REITs in the USA • Ameliorating gains – interest and loss carry overs in the USA
Session / Workshop Chair(s)
| David Jervis | Eversheds Sutherland LLP, London, England |
Speakers
| Albert Collado | Garrigues, Madrid, Spain |
| Dr Michaela Engel | Noerr, Munich, Germany |
| David R Hardy | McDermott Will and Emery, New York, New York, USA; Treasurer, IBA Foundation |
| Antti Lehtimaja | Krogerus, Helsinki, Finland |
| Barbara Worndl | Aird & Berlis LLP, Toronto, Ontario, Canada |
| Rutger Zaal | AKD , Luxembourg City, Luxembourg |